TPO cannot introduce new adjustment in current AY without consistency from prior years for identical transactions: ITAT

ITAT ruled that a Transfer Pricing Officer (TPO) cannot introduce a new adjustment in the current assessment year without consistency from prior years for identical transactions. This decision emphasizes the principle of consistency in transfer pricing adjustments. It ensures that TPOs adhere to established methodologies and avoid arbitrary adjustments. This ruling provides clarity and predictability for taxpayers regarding transfer pricing assessments. It promotes fairness and transparency in international taxation.