https://www.taxtmi.com/caselaws?id=313942 Transfer pricing on corporate guarantees turned on determining the arm's length guarantee commission. Following its own order for earlier AYs and relying on the bank's rate, the ITAT sustained 0.60% as the ALP for all corporate guarantees, including one where no subsequent comparable material was produced; the assessee's ground was partly allowed. Addition based on higher turnover in service tax returns depended on whether receipts were revenue or advances. Applying accrual principles, the ITAT held that amounts shown in ST-3 as advances could not be taxed as current-year revenue and rejected the CIT(A)'s percentage-completion approach; the addition was deleted and the ground allowed. On fresh deduction claims, appellate power was affirmed per SC in Goetze, and the matter was remanded to the AO for verification; remand for statistical purposes. en-us Wed, 13 Sep 2023 00:00:00 +0530 Mon, 05 Jan 2026 13:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313942 Transfer pricing on corporate guarantees turned on determining the arm's length guarantee commission. Following its own order for earlier AYs and relying on the bank's rate, the ITAT sustained 0.60% as the ALP for all corporate guarantees, including one where no subsequent comparable material was produced; the assessee's ground was partly allowed. Addition based on higher turnover in service tax returns depended on whether receipts were revenue or advances. Applying accrual principles, the ITAT held that amounts shown in ST-3 as advances could not be taxed as current-year revenue and rejected the CIT(A)'s percentage-completion approach; the addition was deleted and the ground allowed. On fresh deduction claims, appellate power was affirmed per SC in Goetze, and the matter was remanded to the AO for verification; remand for statistical purposes. Case-Laws Income Tax Wed, 13 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313942