https://www.taxtmi.com/caselaws?id=431262 The Tribunal partially allowed the appeal by directing the deletion of the Transfer Pricing adjustment of Rs. 2,84,73,482 related to profit attributable to intangible assets. This decision was based on the Tribunal's earlier ruling that there was no international transaction during the relevant assessment year. However, the Tribunal upheld the addition of Rs. 1,69,66,363 concerning the commission on the corporate guarantee, agreeing with the DRP's assessment that the 1.6% rate was appropriate considering the risks involved in providing the guarantee. en-us Thu, 23 Jun 2022 00:00:00 +0530 Thu, 08 Dec 2022 13:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=431262 The Tribunal partially allowed the appeal by directing the deletion of the Transfer Pricing adjustment of Rs. 2,84,73,482 related to profit attributable to intangible assets. This decision was based on the Tribunal's earlier ruling that there was no international transaction during the relevant assessment year. However, the Tribunal upheld the addition of Rs. 1,69,66,363 concerning the commission on the corporate guarantee, agreeing with the DRP's assessment that the 1.6% rate was appropriate considering the risks involved in providing the guarantee. Case-Laws Income Tax Thu, 23 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=431262