https://www.taxtmi.com/caselaws?id=406138 The Tribunal upheld that the financial guarantees given by the assessee to its Associated Enterprises constitute "international transactions" under the Income Tax Act. It supported the assessee's methodology for determining the Arm's Length Price (ALP) of the financial guarantees, rejecting the Transfer Pricing Officer's ad hoc determination. The Tribunal also directed the TPO to vacate arbitrary adjustments and upheld the ALP determined by the assessee. Additionally, the Tribunal emphasized consistency with previous orders and directed the reassessment of disallowances and interest calculations in line with legal provisions. The appeals for the relevant assessment years were allowed based on these findings. en-us Mon, 05 Apr 2021 00:00:00 +0530 Wed, 07 Apr 2021 09:18:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406138 The Tribunal upheld that the financial guarantees given by the assessee to its Associated Enterprises constitute "international transactions" under the Income Tax Act. It supported the assessee's methodology for determining the Arm's Length Price (ALP) of the financial guarantees, rejecting the Transfer Pricing Officer's ad hoc determination. The Tribunal also directed the TPO to vacate arbitrary adjustments and upheld the ALP determined by the assessee. Additionally, the Tribunal emphasized consistency with previous orders and directed the reassessment of disallowances and interest calculations in line with legal provisions. The appeals for the relevant assessment years were allowed based on these findings. Case-Laws Income Tax Mon, 05 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406138