https://www.taxtmi.com/caselaws?id=426242 The Tribunal directed the Transfer Pricing Officer (TPO) to determine the Arm's Length Price (ALP) for international sales to Associated Enterprises (AEs) by considering only export sales to AEs, including foreign exchange gain in operating profit, and maintaining a 25% export turnover filter. Additionally, the ALP for a corporate guarantee provided without commission was set at 0.5% of the utilized credit limit, resulting in a partial allowance of the Assessee's appeal with instructions for the TPO to re-determine the ALP accordingly. en-us Wed, 27 Apr 2022 00:00:00 +0530 Tue, 09 Aug 2022 21:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=426242 The Tribunal directed the Transfer Pricing Officer (TPO) to determine the Arm's Length Price (ALP) for international sales to Associated Enterprises (AEs) by considering only export sales to AEs, including foreign exchange gain in operating profit, and maintaining a 25% export turnover filter. Additionally, the ALP for a corporate guarantee provided without commission was set at 0.5% of the utilized credit limit, resulting in a partial allowance of the Assessee's appeal with instructions for the TPO to re-determine the ALP accordingly. Case-Laws Income Tax Wed, 27 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=426242