https://www.taxtmi.com/caselaws?id=762967 The ITAT Delhi held that no international transaction existed for corporate guarantee benchmarking purposes in the assessment year. The assessee had previously provided corporate guarantees for step-down subsidiaries' loans totaling USD 95 million from EXIM bank. However, when the subsidiaries defaulted and loans became NPAs, the bank initiated recovery proceedings against the assessee as guarantor in May 2016. The tribunal found that since the assessee was aware of the default situation and the guarantee crystallized into actual liability at the beginning of the assessment year, no subsisting guarantee existed during the relevant period. Consequently, the TPO erred in initiating transfer pricing proceedings, and the proposed addition was directed to be deleted. en-us Fri, 05 Jul 2024 00:00:00 +0530 Wed, 11 Dec 2024 08:15:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762967 The ITAT Delhi held that no international transaction existed for corporate guarantee benchmarking purposes in the assessment year. The assessee had previously provided corporate guarantees for step-down subsidiaries' loans totaling USD 95 million from EXIM bank. However, when the subsidiaries defaulted and loans became NPAs, the bank initiated recovery proceedings against the assessee as guarantor in May 2016. The tribunal found that since the assessee was aware of the default situation and the guarantee crystallized into actual liability at the beginning of the assessment year, no subsisting guarantee existed during the relevant period. Consequently, the TPO erred in initiating transfer pricing proceedings, and the proposed addition was directed to be deleted. Case-Laws Income Tax Fri, 05 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762967