The Tax Publishers2022 TaxPub(DT) 5939 (Chen-Trib)

INCOME TAX ACT, 1961

Section 92B

After amendment of section 92B corporate guarantee given by assessee to its AE was an international transaction.

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

Assessee extended corporate guarantee to its AE abroad, without charging any fee. TPO proposed ALP adjustment. Assessee pleaded that corporate guarantee extended by assessee to its AE was not an international transaction. Held: After amendment of section 92B expanding the definition of international transaction. Corporate guarantee given by assesse to its AE was an international transaction.

REFERRED :

FAVOUR : Against the assessee.

A.Y. : 2008-09 to 2011-12


INCOME TAX ACT, 1961

Section 92C

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