https://www.taxtmi.com/caselaws?id=366557 Corporate guarantee commission for an associated enterprise could not be benchmarked against bank guarantees, so the 0.5% arm's length rate was not disturbed on transfer pricing grounds. Share application money was not re-characterised as a loan merely because share issuance was delayed, since the delay was explained and there was no basis to treat the funds as debt. Section 10A deduction issues on set-off of non-STPI losses and carry forward questions were covered by binding precedent on computation, leaving no substantial question of law. The Revenue's challenge therefore failed on all grounds. en-us Tue, 04 Sep 2018 00:00:00 +0530 Thu, 06 Sep 2018 10:28:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=366557 Corporate guarantee commission for an associated enterprise could not be benchmarked against bank guarantees, so the 0.5% arm's length rate was not disturbed on transfer pricing grounds. Share application money was not re-characterised as a loan merely because share issuance was delayed, since the delay was explained and there was no basis to treat the funds as debt. Section 10A deduction issues on set-off of non-STPI losses and carry forward questions were covered by binding precedent on computation, leaving no substantial question of law. The Revenue's challenge therefore failed on all grounds. Case-Laws Income Tax Tue, 04 Sep 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=366557