https://www.taxtmi.com/caselaws?id=434868 Transfer pricing dispute addressed use of CUP versus TNMM for benchmarking international software consultancy transactions with associated enterprises; consistency in methodology was upheld and CUP was directed to be applied, resulting in deletion of the TP adjustment on AE sales. Corporate guarantees to AEs were held to constitute international transactions requiring benchmarking; bank guarantee rates are inapposite and guarantee commission depends on transaction-specific risk. Applying precedent, the TPO was directed to benchmark corporate guarantee fees at 0.5% of the guarantee amount. Appeal was partly allowed with corresponding directions to recalculate adjustments. en-us Wed, 21 Sep 2022 00:00:00 +0530 Wed, 28 Jan 2026 16:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434868 Transfer pricing dispute addressed use of CUP versus TNMM for benchmarking international software consultancy transactions with associated enterprises; consistency in methodology was upheld and CUP was directed to be applied, resulting in deletion of the TP adjustment on AE sales. Corporate guarantees to AEs were held to constitute international transactions requiring benchmarking; bank guarantee rates are inapposite and guarantee commission depends on transaction-specific risk. Applying precedent, the TPO was directed to benchmark corporate guarantee fees at 0.5% of the guarantee amount. Appeal was partly allowed with corresponding directions to recalculate adjustments. Case-Laws Income Tax Wed, 21 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434868