https://www.taxtmi.com/caselaws?id=405834 Corporate guarantee furnished to associated enterprises is treated as an international transaction under section 92B, and purported performance guarantees with the same financial exposure are also covered. For arm's length pricing, bank guarantee rates were rejected as an unsuitable benchmark; a 0.5% corporate guarantee commission plus actual out-of-pocket expenses was accepted, and the higher 2% fee was not sustained. In TNMM operating-cost computation, the depreciation figure from the accepted revised return had to be used, while brokerage, commission on fixed deposits, bank charges, loan processing fee and SBLC commission were treated as non-operating finance costs. Transfer pricing adjustment was confined to transactions with associated enterprises only. en-us Fri, 26 Mar 2021 00:00:00 +0530 Fri, 26 Mar 2021 15:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=405834 Corporate guarantee furnished to associated enterprises is treated as an international transaction under section 92B, and purported performance guarantees with the same financial exposure are also covered. For arm's length pricing, bank guarantee rates were rejected as an unsuitable benchmark; a 0.5% corporate guarantee commission plus actual out-of-pocket expenses was accepted, and the higher 2% fee was not sustained. In TNMM operating-cost computation, the depreciation figure from the accepted revised return had to be used, while brokerage, commission on fixed deposits, bank charges, loan processing fee and SBLC commission were treated as non-operating finance costs. Transfer pricing adjustment was confined to transactions with associated enterprises only. Case-Laws Income Tax Fri, 26 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=405834