https://www.taxtmi.com/caselaws?id=413702 The Tribunal rejected the assessee's argument that corporate guarantees are not international transactions but disagreed with the 3% adjustment, directing a 0.5% arm's length consideration based on a jurisdictional High Court precedent. For clinical trial services, the Tribunal upheld the assessee's plea to use segmental margins for comparison, remitting the issue for reassessment at the assessment stage. The appeal was partly allowed, with adjustments made for corporate guarantees and a reconsideration of clinical trial services using segmental results. en-us Thu, 09 Sep 2021 00:00:00 +0530 Tue, 19 Oct 2021 12:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=413702 The Tribunal rejected the assessee's argument that corporate guarantees are not international transactions but disagreed with the 3% adjustment, directing a 0.5% arm's length consideration based on a jurisdictional High Court precedent. For clinical trial services, the Tribunal upheld the assessee's plea to use segmental margins for comparison, remitting the issue for reassessment at the assessment stage. The appeal was partly allowed, with adjustments made for corporate guarantees and a reconsideration of clinical trial services using segmental results. Case-Laws Income Tax Thu, 09 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=413702