https://www.taxtmi.com/caselaws?id=753055 The ITAT Hyderabad upheld corporate guarantee commission at 0.53% instead of AO's 1.8% rate, following precedent in Aurobinda Pharma case. The tribunal confirmed corporate guarantees to foreign AEs constitute international transactions requiring benchmarking. For trade receivables, 60-day credit period was maintained with 6% SBI interest rate on delayed payments. Two comparable companies were excluded from transfer pricing analysis as agreed by both parties. The matter was remanded to AO/TPO for fresh determination after excluding R&D, head office, and marketing expenses from comparable companies' financials, with directions to provide proper hearing opportunity and consider segmental accounts of non-exempt units. en-us Tue, 21 May 2024 00:00:00 +0530 Thu, 23 May 2024 22:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753055 The ITAT Hyderabad upheld corporate guarantee commission at 0.53% instead of AO's 1.8% rate, following precedent in Aurobinda Pharma case. The tribunal confirmed corporate guarantees to foreign AEs constitute international transactions requiring benchmarking. For trade receivables, 60-day credit period was maintained with 6% SBI interest rate on delayed payments. Two comparable companies were excluded from transfer pricing analysis as agreed by both parties. The matter was remanded to AO/TPO for fresh determination after excluding R&D, head office, and marketing expenses from comparable companies' financials, with directions to provide proper hearing opportunity and consider segmental accounts of non-exempt units. Case-Laws Income Tax Tue, 21 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753055