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The ITAT addressed two main issues: 1. TP Adjustment for...
ITAT says corporate guarantee to AE is not a financial service by assessee. No profit shifting or burden. Interest adjustment on AEs' receivables unjustified.
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The ITAT addressed two main issues: 1. TP Adjustment for corporate guarantee to AE: As the assessee did not provide guarantees to unrelated parties, it was not a financial service. The low profit rate of AE and adequate security indicated no profit shifting. Citing PCIT Vs Redington, the adjustment was deleted as it did not affect the assessee's finances. 2. Addition of interest on overdue receivables from AEs: TPO applied a 60-day credit policy, contrary to the assessee's 180-day policy in line with RBI guidelines. Following GSS Infotech Ltd, interest was not charged to AEs or non-AEs, so adding notional interest was unjustified. Referring to CIT Vs Indo American Jewellery Ltd, the interest adjustment was deleted.
The ITAT addressed two main issues: 1. TP Adjustment for corporate guarantee to AE: As the assessee did not provide guarantees to unrelated parties, it was not a financial service. The low profit rate of AE and adequate security indicated no profit shifting. Citing PCIT Vs Redington, the adjustment was deleted as it did not affect the assessee's finances. 2. Addition of interest on overdue receivables from AEs: TPO applied a 60-day credit policy, contrary to the assessee's 180-day policy in line with RBI guidelines. Following GSS Infotech Ltd, interest was not charged to AEs or non-AEs, so adding notional interest was unjustified. Referring to CIT Vs Indo American Jewellery Ltd, the interest adjustment was deleted.
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