https://www.taxtmi.com/caselaws?id=392114 The tribunal upheld the Commissioner of Income Tax (Appeals) [CIT(A)]'s decisions on all grounds, dismissing the Revenue's appeal. The corporate guarantee provided by the assessee to its subsidiaries was not considered an international transaction for Transfer Pricing (TP) adjustment purposes. The adjustment proposed on interest receivables was deleted as no separate benchmark was required, and the ALP adjustment on the sale of instant coffee was deemed unjustified. The tribunal found no profit shifting to the associated enterprise and concluded that the CIT(A)'s decisions were consistent with previous rulings and the case facts. en-us Tue, 07 Jan 2020 00:00:00 +0530 Mon, 10 Feb 2020 16:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=392114 The tribunal upheld the Commissioner of Income Tax (Appeals) [CIT(A)]'s decisions on all grounds, dismissing the Revenue's appeal. The corporate guarantee provided by the assessee to its subsidiaries was not considered an international transaction for Transfer Pricing (TP) adjustment purposes. The adjustment proposed on interest receivables was deleted as no separate benchmark was required, and the ALP adjustment on the sale of instant coffee was deemed unjustified. The tribunal found no profit shifting to the associated enterprise and concluded that the CIT(A)'s decisions were consistent with previous rulings and the case facts. Case-Laws Income Tax Tue, 07 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=392114