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The Tax PublishersITA No. 2750/Mum/2014
2020 TaxPub(DT) 4696 (Mum-Trib)INCOME TAX ACT, 1961
Section 92C
Corporate Guarantee facility provided to overseas AE by assessee was an international transaction. In so far as rate of commission was concerned, corporate guarantee commission @ 0.5% would be at arm's length.
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Transfer pricing - International transaction - Determination of ALP - Provision of Corporate Guarantee for AE
TPO suggested ALP adjustment on account of Corporate Guarantee facility provided by assessee for its overseas AE, considering 8% guarantee commission as at arm's length. Assessee contended that provision for Corporate Guarantee for its AE was not an international transaction. Held: Corporate Guarantee facility provided to overseas AE by assessee was an international transaction. In so far as rate of commission was concerned, corporate guarantee commission @ 0.5% would be at arm's length.
Relied:CIT v. Everest Kento Cylinders Ltd. (2015) 58 Taxmann.com 254 (Bom) : (2015) 232 Taxman 307 (Bom) : (2015) 378 ITR 57 (Bom) : 2015 TaxPub(DT) 2547 (Bom-HC).
REFERRED :
FAVOUR : Partly in assessee's favour.
A.Y. : 2008-09
INCOME TAX ACT, 1961
Section 92C
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