https://www.taxtmi.com/caselaws?id=274222 The Tribunal partly allowed the assessee's appeal, directing the Transfer Pricing Officer (TPO) and Assessing Officer (AO) to re-assess the arm's length price of the loan and delete the addition for the corporate guarantee. The Tribunal found that the loan provided to Tega Bahamas was quasi-equity and should be benchmarked using the Comparable Uncontrolled Price (CUP) method, rejecting the TPO's methodology. Additionally, the Tribunal determined that the corporate guarantee was a shareholder activity aimed at protecting the assessee's investment, not subject to transfer pricing adjustments. en-us Wed, 21 Sep 2016 00:00:00 +0530 Tue, 04 Aug 2026 18:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=274222 The Tribunal partly allowed the assessee's appeal, directing the Transfer Pricing Officer (TPO) and Assessing Officer (AO) to re-assess the arm's length price of the loan and delete the addition for the corporate guarantee. The Tribunal found that the loan provided to Tega Bahamas was quasi-equity and should be benchmarked using the Comparable Uncontrolled Price (CUP) method, rejecting the TPO's methodology. Additionally, the Tribunal determined that the corporate guarantee was a shareholder activity aimed at protecting the assessee's investment, not subject to transfer pricing adjustments. Case-Laws Income Tax Wed, 21 Sep 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=274222