https://www.taxtmi.com/caselaws?id=404526 The Tribunal partly allowed the appeal, directing adjustments on arm's length interest, corporate guarantee fee, and disallowance on non-genuine purchases. It upheld the Commissioner (Appeals) decisions on applying LIBOR rate for interest calculation and fee rate for corporate guarantee, while restricting the disallowance to 3% on purchases from one entity. The Tribunal considered shareholder activity of capital funding as an international transaction and emphasized the need for detailed analysis and legal interpretations in determining adjustments. en-us Tue, 16 Feb 2021 00:00:00 +0530 Wed, 24 Feb 2021 10:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=404526 The Tribunal partly allowed the appeal, directing adjustments on arm's length interest, corporate guarantee fee, and disallowance on non-genuine purchases. It upheld the Commissioner (Appeals) decisions on applying LIBOR rate for interest calculation and fee rate for corporate guarantee, while restricting the disallowance to 3% on purchases from one entity. The Tribunal considered shareholder activity of capital funding as an international transaction and emphasized the need for detailed analysis and legal interpretations in determining adjustments. Case-Laws Income Tax Tue, 16 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=404526