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| The Tax Publishers2019 TaxPub(DT) 1045 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
Corporate guarantee commission @ 1% of the outstanding guarantee amount had to be considered as at arm's length as against 1.75% considered by TPO.
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Transfer pricing - Determination of ALP - Corporate guarantee commission to be charged from AE -
Assessee had given corporate guarantee to Axis Bank to extend foreign currency loan to its AE abroad. TPO based on ad hoc credit rating of assessee and its AE considered guuarantee commission @ 1.75% as at arm's length. Held: Corporate guarantee commission @ 1% of the outstanding guarantee amount had to be considered as at arm's length.
REFERRED :
FAVOUR : Parly in assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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