https://www.taxtmi.com/caselaws?id=271144 The Tribunal partly allowed the appeals of both parties for statistical purposes. Key points include using LIBOR PLUS for interest benchmarking on international transactions and remitting the corporate guarantee fee issue back to the TPO for recalculating the ALP at a potentially lower rate. Disallowances on selling, distribution, repairs, and maintenance expenses were upheld, while the TDS & TCS credit issue was sent back for further examination. The levy of interest under Section 234B and on TP adjustments due to retrospective amendments was upheld as automatic and consequential. en-us Fri, 04 Dec 2015 00:00:00 +0530 Thu, 28 Jan 2016 10:03:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=271144 The Tribunal partly allowed the appeals of both parties for statistical purposes. Key points include using LIBOR PLUS for interest benchmarking on international transactions and remitting the corporate guarantee fee issue back to the TPO for recalculating the ALP at a potentially lower rate. Disallowances on selling, distribution, repairs, and maintenance expenses were upheld, while the TDS & TCS credit issue was sent back for further examination. The levy of interest under Section 234B and on TP adjustments due to retrospective amendments was upheld as automatic and consequential. Case-Laws Income Tax Fri, 04 Dec 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=271144