https://www.taxtmi.com/caselaws?id=406652 ITAT Chennai-AT decided multiple transfer pricing and tax issues. Corporate guarantee fees were held to constitute international transactions under Section 92B, with guarantee commission fixed at 0.50% instead of AO's 1.04% rate based on commercial bank comparables. Interest expenditure disallowance on borrowed funds for subsidiary investment was remitted to AO following consistency principle from prior years. TDS under Section 195 on offshore services was remitted for fresh examination considering twin criteria of service rendering and utilization in India. Tax credit denial under Section 90 was remitted to AO for re-examination. Forex loss disallowance was set aside and remitted for reconsideration with proper documentation. Section 14A disallowance was remitted for fresh examination regarding borrowed funds utilization. Long-term capital loss disallowance on subsidiary share buyback was remitted to AO for proper examination of transaction details. Professional consultancy services disallowance was remitted to verify recipient's tax treatment and service details. en-us Mon, 12 Apr 2021 00:00:00 +0530 Mon, 05 May 2025 12:38:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406652 ITAT Chennai-AT decided multiple transfer pricing and tax issues. Corporate guarantee fees were held to constitute international transactions under Section 92B, with guarantee commission fixed at 0.50% instead of AO's 1.04% rate based on commercial bank comparables. Interest expenditure disallowance on borrowed funds for subsidiary investment was remitted to AO following consistency principle from prior years. TDS under Section 195 on offshore services was remitted for fresh examination considering twin criteria of service rendering and utilization in India. Tax credit denial under Section 90 was remitted to AO for re-examination. Forex loss disallowance was set aside and remitted for reconsideration with proper documentation. Section 14A disallowance was remitted for fresh examination regarding borrowed funds utilization. Long-term capital loss disallowance on subsidiary share buyback was remitted to AO for proper examination of transaction details. Professional consultancy services disallowance was remitted to verify recipient's tax treatment and service details. Case-Laws Income Tax Mon, 12 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406652