https://www.taxtmi.com/caselaws?id=255352 The tribunal partly allowed the appeal, directing the AO to rework the interest on loans at LIBOR + 2.75% and to adopt a 0.53% rate for the guarantee commission. The adjustments were upheld in principle, but the rates were modified to align with comparable transactions. The tribunal emphasized the inherent risk in providing guarantees and the need for ALP determination under TP provisions. The decision reflects a balanced approach, considering both the retrospective amendment to section 92B and the commercial realities of the transactions. en-us Wed, 31 Dec 2014 00:00:00 +0530 Thu, 15 Jan 2015 08:01:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=255352 The tribunal partly allowed the appeal, directing the AO to rework the interest on loans at LIBOR + 2.75% and to adopt a 0.53% rate for the guarantee commission. The adjustments were upheld in principle, but the rates were modified to align with comparable transactions. The tribunal emphasized the inherent risk in providing guarantees and the need for ALP determination under TP provisions. The decision reflects a balanced approach, considering both the retrospective amendment to section 92B and the commercial realities of the transactions. Case-Laws Income Tax Wed, 31 Dec 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=255352