https://www.taxtmi.com/caselaws?id=284979 The Tribunal remanded the determination of arm's length price for an international transaction involving a loan in US Dollars to the AO due to insufficient details. The issue of commission rate for providing a guarantee was remanded to the TPO, rejecting the argument that a corporate guarantee is not an international transaction. The Tribunal recalled its order on disallowance under section 14A to address the computation of average investment value. Royalty income exclusion from business income for deduction under section 10A was found to lack a direct nexus and required further adjudication. The treatment of expenses in foreign currency for export turnover deduction and non-adjudication of specific grounds were also revisited for comprehensive review. en-us Fri, 28 Jun 2019 00:00:00 +0530 Fri, 20 Dec 2019 09:55:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=284979 The Tribunal remanded the determination of arm's length price for an international transaction involving a loan in US Dollars to the AO due to insufficient details. The issue of commission rate for providing a guarantee was remanded to the TPO, rejecting the argument that a corporate guarantee is not an international transaction. The Tribunal recalled its order on disallowance under section 14A to address the computation of average investment value. Royalty income exclusion from business income for deduction under section 10A was found to lack a direct nexus and required further adjudication. The treatment of expenses in foreign currency for export turnover deduction and non-adjudication of specific grounds were also revisited for comprehensive review. Case-Laws Income Tax Fri, 28 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=284979