https://www.taxtmi.com/caselaws?id=305796 The Tribunal remanded the case to the Transfer Pricing Officer (TPO) to benchmark the payment for corporate guarantee fees as an international transaction, rejecting the TPO's characterization of the transaction as a shareholder activity. The Tribunal emphasized that providing a corporate guarantee constitutes an international transaction under the Income Tax Act and directed proper benchmarking in line with legal definitions and precedents. The decision underscored the significance of adhering to established legal principles in transfer pricing assessments for accurate determination of arm's length prices. en-us Mon, 14 Mar 2022 00:00:00 +0530 Sat, 24 Dec 2022 11:08:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=305796 The Tribunal remanded the case to the Transfer Pricing Officer (TPO) to benchmark the payment for corporate guarantee fees as an international transaction, rejecting the TPO's characterization of the transaction as a shareholder activity. The Tribunal emphasized that providing a corporate guarantee constitutes an international transaction under the Income Tax Act and directed proper benchmarking in line with legal definitions and precedents. The decision underscored the significance of adhering to established legal principles in transfer pricing assessments for accurate determination of arm's length prices. Case-Laws Income Tax Mon, 14 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=305796