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| The Tax Publishers2021 TaxPub(DT) 5924 (Hyd-Trib) INCOME TAX ACT, 1961
Section 92B
Corporate Guarantee is covered by the definition of 'international transaction' after retrospective amendment made by Finance Act, 2012. Therefore, TPO rightly treated the assessee's corporate guarantee(s) in all the three concerned assessment years as an international transaction falling under section 92B.
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Transfer pricing - International transaction - Corporate guarantee -
Assessee extended corporate guarantee in favour of overseas AE. TPO considered the same as an international transaction calling for TP adjustment. Assessee challenged this. Held: Corporate Guarantee is covered by the definition of 'international transaction' after retrospective amendment made by Finance Act, 2012. Therefore, TPO rightly treated the assessee's corporate guarantee(s) in all the three concerned assessment years as an international transaction falling under section 92B.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2016-17 & 2017-18
INCOME TAX ACT, 1961
Section 36(1)(va) Section 43B, Proviso
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