https://www.taxtmi.com/caselaws?id=755957 Transfer pricing treatment of guarantee fee paid to an associated enterprise was examined on the basis of whether the borrowing cost, including the guarantee commission, was lower than the relevant bank rate and whether the arrangement conferred an economic benefit. On identical facts, the same adjustment had already been deleted for an earlier assessment year and that view had been upheld in further proceedings. Applying those facts, the guarantee commission was found to be at arm's length and the arm's length price could not be benchmarked at nil on a generalised objection to the need for a guarantee. The transfer pricing adjustment was therefore deleted. en-us Fri, 12 Jul 2024 00:00:00 +0530 Tue, 23 Jul 2024 09:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755957 Transfer pricing treatment of guarantee fee paid to an associated enterprise was examined on the basis of whether the borrowing cost, including the guarantee commission, was lower than the relevant bank rate and whether the arrangement conferred an economic benefit. On identical facts, the same adjustment had already been deleted for an earlier assessment year and that view had been upheld in further proceedings. Applying those facts, the guarantee commission was found to be at arm's length and the arm's length price could not be benchmarked at nil on a generalised objection to the need for a guarantee. The transfer pricing adjustment was therefore deleted. Case-Laws Income Tax Fri, 12 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755957