https://www.taxtmi.com/caselaws?id=176130 Arm's Length Price dispute on guarantee commission: the CUPs derived from bank guarantee commissions were rejected as external comparables, and the assessee's charged corporate guarantee rates of 0.53% and 1.47% were found to be reliable, leading to deletion of transfer pricing additions and setting aside of TP adjustments. The claim for a research and development deduction was allowed, with the alternate depreciation claim refused as unsustainable in light of the R&D allowance. Export benefit claim for duty entitlement pass-through licenses was disallowed. Interest on enhanced book profits under the minimum tax regime was held not leviable. en-us Wed, 13 Nov 2013 00:00:00 +0530 Sat, 24 Jan 2026 11:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=176130 Arm's Length Price dispute on guarantee commission: the CUPs derived from bank guarantee commissions were rejected as external comparables, and the assessee's charged corporate guarantee rates of 0.53% and 1.47% were found to be reliable, leading to deletion of transfer pricing additions and setting aside of TP adjustments. The claim for a research and development deduction was allowed, with the alternate depreciation claim refused as unsustainable in light of the R&D allowance. Export benefit claim for duty entitlement pass-through licenses was disallowed. Interest on enhanced book profits under the minimum tax regime was held not leviable. Case-Laws Income Tax Wed, 13 Nov 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=176130