Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
The Appellate Tribunal partly allowed the assessee's appeal concerning the transfer pricing adjustment on corporate guarantee fees for international transactions. The Tribunal rejected the Transfer Pricing Officer's benchmarking based on Indian bank rates since the Associated Enterprise obtained a loan from a Saudi Arabian bank. Considering the consistent approach of coordinate Benches, the Tribunal directed the Assessing Officer to restrict the arm's length price adjustment to 0.5% for the corporate guarantee fees.
The Appellate Tribunal partly allowed the assessee's appeal concerning the transfer pricing adjustment on corporate guarantee fees for international transactions. The Tribunal rejected the Transfer Pricing Officer's benchmarking based on Indian bank rates since the Associated Enterprise obtained a loan from a Saudi Arabian bank. Considering the consistent approach of coordinate Benches, the Tribunal directed the Assessing Officer to restrict the arm's length price adjustment to 0.5% for the corporate guarantee fees.
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