https://www.taxtmi.com/caselaws?id=302699 Corporate guarantee provided to an associated enterprise is treated as an international transaction under Chapter X transfer pricing provisions, with retrospective support under the statutory explanation to section 92B. The arm's length commission for the guarantee was benchmarked by reference to comparable guarantee pricing and moderated from 2% to 0.875%, while the assessee's plea for 0.5% was rejected. The adjustment on interest receivables was deleted because it was based on a domestic deposit rate rather than a proper transfer pricing benchmark, and no comparable uncontrolled transaction supported the addition. en-us Thu, 23 Sep 2021 00:00:00 +0530 Sun, 12 Jun 2022 21:14:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=302699 Corporate guarantee provided to an associated enterprise is treated as an international transaction under Chapter X transfer pricing provisions, with retrospective support under the statutory explanation to section 92B. The arm's length commission for the guarantee was benchmarked by reference to comparable guarantee pricing and moderated from 2% to 0.875%, while the assessee's plea for 0.5% was rejected. The adjustment on interest receivables was deleted because it was based on a domestic deposit rate rather than a proper transfer pricing benchmark, and no comparable uncontrolled transaction supported the addition. Case-Laws Income Tax Thu, 23 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=302699