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ITAT partially allowed assessee's appeal regarding transfer pricing (TP) adjustment for corporate guarantee. The Tribunal held the corporate guarantee as an international transaction and directed the TPO/AO to compute the guarantee fee at 0.5% rate, deleting excess amount added. Regarding interest under section 244A, the Tribunal directed the assessee to approach the AO, who shall consider the interest claim in accordance with law, with the Principal Commissioner having final decision-making authority on interest period and calculation.
ITAT partially allowed assessee's appeal regarding transfer pricing (TP) adjustment for corporate guarantee. The Tribunal held the corporate guarantee as an international transaction and directed the TPO/AO to compute the guarantee fee at 0.5% rate, deleting excess amount added. Regarding interest under section 244A, the Tribunal directed the assessee to approach the AO, who shall consider the interest claim in accordance with law, with the Principal Commissioner having final decision-making authority on interest period and calculation.
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