https://www.taxtmi.com/caselaws?id=763240 The ITAT Delhi held that a corporate guarantee transaction with EXIM Bank did not constitute an international transaction under transfer pricing provisions. The tribunal ruled that once the guarantee was invoked, the transaction remained between the assessee and EXIM Bank (unrelated parties), not with the associated enterprise. The court distinguished that while subrogation creates rights against the principal debtor, it does not create a new debt that would transform the guarantee into a deemed loan to the associated enterprise requiring arm's length interest charges. The assessee's appeal was allowed. en-us Fri, 13 Dec 2024 00:00:00 +0530 Mon, 16 Dec 2024 08:44:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763240 The ITAT Delhi held that a corporate guarantee transaction with EXIM Bank did not constitute an international transaction under transfer pricing provisions. The tribunal ruled that once the guarantee was invoked, the transaction remained between the assessee and EXIM Bank (unrelated parties), not with the associated enterprise. The court distinguished that while subrogation creates rights against the principal debtor, it does not create a new debt that would transform the guarantee into a deemed loan to the associated enterprise requiring arm's length interest charges. The assessee's appeal was allowed. Case-Laws Income Tax Fri, 13 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763240