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| The Tax Publishers2020 TaxPub(DT) 3576 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
Where Assessee extended corporate guarantee in favour of AE abroad TPO was directed to restrict adjustment on account of corporate guarantee commission @ 0.5% as against 1.25% adopted by assessee.
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Transfer pricing - Determination of ALP - Provision of corporate guarantee to AE -
Assessee extended corporate guarantee in favour of its AE abroad, however, without charging any guarantee fee. TPO considered 1.25% guarantee fee as at arm's length and accordingly, suggested ALP adjustment. Held: TPO was directed to restrict adjustment on account of corporate guarantee @ 0.5% till the time it was availed of during the year.
Followed:CIT v. Everest Kanto Cylinder Ltd. (2015) 378 ITR 57 (Bom) : 2015 TaxPub(DT) 2547 (Bom-HC).
REFERRED :
FAVOUR : Partly in assessee's favour.
A.Y. : 2014-15
INCOME TAX ACT, 1961
Section 92C
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