Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
