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The Tax PublishersITA Nos. 778, 867 of 2017
2019 TaxPub(DT) 7274 (Bom-HC) : (2019) 267 TAXMAN 0625INCOME TAX ACT, 1961
Section 92C
Considerations which applied for issuance of a corporate guarantee for benefit of subsidiary company are distinct and separate from that of bank guarantee and accordingly corporate guarantee commission could not be called into question.
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Transfer pricing - Determination of ALP - Issuance of corporate guarantee -
Assessee issued corporate guarantee for the benefit of foreign subsidiary company. TPO determined ALP of guarante commission charges taking into consideration entity, country specific, currency risks and also considering leverated position taken by the company which had an impact on its working capital. Held: Considerations which applied for issuance of a corporate guarantee for benefit of subsidiary company are distinct and separate from that of bank guarantee and accordingly corporate guarantee commission could not be called into question.
REFERRED :
FAVOUR : In assessee's favour
A.Y. :
INCOME TAX ACT, 1961
Section 36(1)(iii)
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