https://www.taxtmi.com/caselaws?id=310200 The Tribunal held that a corporate guarantee furnished by the assessee for its AE constituted an "international transaction" under s.92B, as the statutory Explanation expressly includes guarantees; accordingly, the TP adjustment on this count was sustainable in principle. On ALP, it rejected comparison with bank charges paid by the assessee, holding a third party would not assume comparable risk; following co-ordinate bench precedent, it restricted the guarantee commission adjustment to 0.5% of the guaranteed amount. On interest on AE receivables, it directed computation of notional interest at 6% on receivables outstanding beyond 60 days, thereby sustaining adjustment on that basis. On s.35(2AB), it allowed weighted deduction for clinical trial expenditure outside approved facilities, since Form 3CL approval covered such spend. en-us Thu, 27 Apr 2023 00:00:00 +0530 Mon, 05 Jan 2026 12:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310200 The Tribunal held that a corporate guarantee furnished by the assessee for its AE constituted an "international transaction" under s.92B, as the statutory Explanation expressly includes guarantees; accordingly, the TP adjustment on this count was sustainable in principle. On ALP, it rejected comparison with bank charges paid by the assessee, holding a third party would not assume comparable risk; following co-ordinate bench precedent, it restricted the guarantee commission adjustment to 0.5% of the guaranteed amount. On interest on AE receivables, it directed computation of notional interest at 6% on receivables outstanding beyond 60 days, thereby sustaining adjustment on that basis. On s.35(2AB), it allowed weighted deduction for clinical trial expenditure outside approved facilities, since Form 3CL approval covered such spend. Case-Laws Income Tax Thu, 27 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310200