https://www.taxtmi.com/highlights?id=79679 Transfer pricing adjustment on international transaction involving payment of guarantee fees to associated enterprise was held unjustified. Assessee demonstrated effective borrowing cost including guarantee fee was lower than bank's quoted interest rate, justifying economic rationale. Tax authorities failed to present compelling evidence against guarantee fee. Benefits of lower interest rates and favorable operating margins substantiated arm's length nature. Tribunal had deleted similar addition previously, upheld by High Court considering consistency in operating margin, benefit of lower borrowing costs compared to bank rates justifying guarantee fee. Present case mirrored facts and circumstances, necessitating consistency in judicial deci..... en-us Wed, 24 Jul 2024 07:38:24 +0530 Wed, 24 Jul 2024 07:38:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=79679 Transfer pricing adjustment on international transaction involving payment of guarantee fees to associated enterprise was held unjustified. Assessee demonstrated effective borrowing cost including guarantee fee was lower than bank's quoted interest rate, justifying economic rationale. Tax authorities failed to present compelling evidence against guarantee fee. Benefits of lower interest rates and favorable operating margins substantiated arm's length nature. Tribunal had deleted similar addition previously, upheld by High Court considering consistency in operating margin, benefit of lower borrowing costs compared to bank rates justifying guarantee fee. Present case mirrored facts and circumstances, necessitating consistency in judicial deci..... Highlights Income Tax Wed, 24 Jul 2024 07:38:24 +0530 https://www.taxtmi.com/highlights?id=79679