Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
The ITAT deleted the addition made by the Assessing Officer (AO) and upheld by the Commissioner of Income Tax (Appeals) [CIT(A)] regarding the adjustment u/s 92CA(3) of the Income Tax Act. The issue pertained to the treatment of a guarantee/standby letter of credit issued by Standard Chartered Bank, New Delhi, as an international transaction. The CIT(A) had upheld the AO's action of adopting an average rate of 2.22% based on rates of nine banks for making the adjustment u/s 92CA(3), instead of the suo-moto adjustment made by the assessee based on the actual cost incurred. The ITAT, considering the voluntary adjustment of 0.94% made by the assessee based on the actual amount paid to Standard Chartered Bank for the bank guarantee, and the smallness of the amount involved, deleted the addition made by the AO to put an end to the litigation.
The ITAT deleted the addition made by the Assessing Officer (AO) and upheld by the Commissioner of Income Tax (Appeals) [CIT(A)] regarding the adjustment u/s 92CA(3) of the Income Tax Act. The issue pertained to the treatment of a guarantee/standby letter of credit issued by Standard Chartered Bank, New Delhi, as an international transaction. The CIT(A) had upheld the AO's action of adopting an average rate of 2.22% based on rates of nine banks for making the adjustment u/s 92CA(3), instead of the suo-moto adjustment made by the assessee based on the actual cost incurred. The ITAT, considering the voluntary adjustment of 0.94% made by the assessee based on the actual amount paid to Standard Chartered Bank for the bank guarantee, and the smallness of the amount involved, deleted the addition made by the AO to put an end to the litigation.
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