https://www.taxtmi.com/caselaws?id=436363 The Income Tax Appellate Tribunal remanded the matter to the Assessing Officer for de novo adjudication regarding the adjustment made on account of the Arm's Length Price (ALP) on corporate guarantees for the assessment years 2009-10 and 2010-11. The Tribunal held that the provision of corporate guarantees constitutes an international transaction under section 92B of the Act, widening the scope post-amendment. The Tribunal emphasized the need for the assessee to contest the determination of the ALP of the guarantee commission on its merits, ensuring a fair opportunity for arguments. Consequently, both appeals were dismissed as no substantial question of law was involved. en-us Mon, 18 Jul 2022 00:00:00 +0530 Tue, 11 Apr 2023 09:12:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436363 The Income Tax Appellate Tribunal remanded the matter to the Assessing Officer for de novo adjudication regarding the adjustment made on account of the Arm's Length Price (ALP) on corporate guarantees for the assessment years 2009-10 and 2010-11. The Tribunal held that the provision of corporate guarantees constitutes an international transaction under section 92B of the Act, widening the scope post-amendment. The Tribunal emphasized the need for the assessee to contest the determination of the ALP of the guarantee commission on its merits, ensuring a fair opportunity for arguments. Consequently, both appeals were dismissed as no substantial question of law was involved. Case-Laws Income Tax Mon, 18 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436363