Sanjiv Khanna, J.

1. The question raised in the present appeal by the Revenue under Section 260A of the Income Tax Act, 1961 (Act, for short) relates to determination of arm’s length rate of interest, paid to the assessed, i.e. Cotton Naturals (I) Pvt. Ltd., by their subsidiary M/s JPC Equestrian, a company registered in the United States of America. The appeal emanates from the order of the Income Tax Appellate Tribunal (Tribunal, for short), dated 30th October, 2013, and pertains to the assessment year 2007- 08.

2. On the basis of the contentions raised by the parties, the following substantial question of law needs to be answered and decided:

1. Whether the Income-Tax Appellate Tribunal was right in following their earlier order for the assessment year 2008-09, dated 8th February, 2013 in ITA No. 5855/Del./2012 and in holding that the interest @ 4% p.a. charged by the respondent assessee from its subsidiary i.e. the Associated Enterprise was arm’s length rate of interest and the adjustment made in the Assessment Order determining the arms’ length rate of interest at 12.2