https://www.taxtmi.com/caselaws?id=327652 The ITAT Mumbai held that the amendment to the transfer pricing provision concerning guarantees issued on behalf of overseas subsidiaries is a specific anti-abuse rule (SAAR) and applies only prospectively from April 1, 2012. Since the assessment year in question predates this effective date, the amended Section 92B does not apply. Consequently, the transfer pricing adjustment related to corporate guarantees was deleted. The tribunal emphasized that anti-abuse provisions require compliant conduct going forward and cannot be applied retrospectively to levy taxes. The decision was in favor of the assessee. en-us Thu, 31 Mar 2016 00:00:00 +0530 Thu, 24 Jul 2025 13:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327652 The ITAT Mumbai held that the amendment to the transfer pricing provision concerning guarantees issued on behalf of overseas subsidiaries is a specific anti-abuse rule (SAAR) and applies only prospectively from April 1, 2012. Since the assessment year in question predates this effective date, the amended Section 92B does not apply. Consequently, the transfer pricing adjustment related to corporate guarantees was deleted. The tribunal emphasized that anti-abuse provisions require compliant conduct going forward and cannot be applied retrospectively to levy taxes. The decision was in favor of the assessee. Case-Laws Income Tax Thu, 31 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327652