https://www.taxtmi.com/caselaws?id=446901 Corporate guarantee fee required fresh treaty characterization before domestic tax treatment could be fixed, because the material did not conclusively establish whether the receipt fell as interest, other income, or business income; the matter was remitted to the Assessing Officer for fresh adjudication. Transfer pricing on interest from external commercial borrowing and related lending also required reconsideration, because the benchmarking exercise had not properly addressed comparability factors such as borrower profile, currency, tenure, purpose, credit risk, and suitable comparables; that issue was likewise sent back for fresh benchmarking and adjudication. Relief was granted to the assessee to that extent by way of remand. en-us Mon, 11 Dec 2023 00:00:00 +0530 Thu, 14 Dec 2023 08:29:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446901 Corporate guarantee fee required fresh treaty characterization before domestic tax treatment could be fixed, because the material did not conclusively establish whether the receipt fell as interest, other income, or business income; the matter was remitted to the Assessing Officer for fresh adjudication. Transfer pricing on interest from external commercial borrowing and related lending also required reconsideration, because the benchmarking exercise had not properly addressed comparability factors such as borrower profile, currency, tenure, purpose, credit risk, and suitable comparables; that issue was likewise sent back for fresh benchmarking and adjudication. Relief was granted to the assessee to that extent by way of remand. Case-Laws Income Tax Mon, 11 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446901