https://www.taxtmi.com/caselaws?id=236771 ITAT held that a bank guarantee constitutes a chargeable service and benefit to Associated Enterprises, so guarantee commission must be at arm's length; it rejected the assessee's stance, upheld CUP methodology but directed AO to compute guarantee commission at 0.5% (partly for Revenue). The tribunal ruled against the assessee on amortised entertainment software expenses for lack of verification by AO. Conversely, ITAT disallowed the TPO's addition for notional interest on overdue commercial balances (2.19% LIBOR) as unsustainable, finding LIBOR inappropriate for commercial overdues and deciding that the addition be deleted. en-us Wed, 12 Jun 2013 00:00:00 +0530 Fri, 07 Nov 2025 16:44:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236771 ITAT held that a bank guarantee constitutes a chargeable service and benefit to Associated Enterprises, so guarantee commission must be at arm's length; it rejected the assessee's stance, upheld CUP methodology but directed AO to compute guarantee commission at 0.5% (partly for Revenue). The tribunal ruled against the assessee on amortised entertainment software expenses for lack of verification by AO. Conversely, ITAT disallowed the TPO's addition for notional interest on overdue commercial balances (2.19% LIBOR) as unsustainable, finding LIBOR inappropriate for commercial overdues and deciding that the addition be deleted. Case-Laws Income Tax Wed, 12 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236771