The Tax Publishers2019 TaxPub(DT) 8396 (Kol-Trib)

INCOME TAX ACT, 1961

Section 92B

Corporate guarantee provided to overseas AE did not amount to international transaction.

Transfer pricing - International transaction - Extension of corporate guarantee to AE -

Assessee extended corporate guarantee to its AE abroad. TPO treated this as international transaction calling for ALP adjustment.Held: Corporate guarantee provided to its overseas AE did not amount to international transaction.

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2012-13

INCOME TAX ACT, 1961

Section 14A Section 115JB

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