https://www.taxtmi.com/caselaws?id=765608 ITAT held that the assessee's characterization as KPO versus software developer was not decided by TPO/DRP for lack of reasons, leaving the issue open and allowing the ground for statistical purposes. TPO/AO was directed to restrict corporate guarantee charges to the actual guarantee periods and recompute them. The Tribunal rejected applying 1.90% (or 1.67%) and adopted 0.53% as the appropriate corporate guarantee rate, directing recomputation accordingly. A letter of comfort was treated as equivalent to a corporate guarantee and must be benchmarked at 0.53%. en-us Mon, 06 Jan 2025 00:00:00 +0530 Tue, 16 Sep 2025 17:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765608 ITAT held that the assessee's characterization as KPO versus software developer was not decided by TPO/DRP for lack of reasons, leaving the issue open and allowing the ground for statistical purposes. TPO/AO was directed to restrict corporate guarantee charges to the actual guarantee periods and recompute them. The Tribunal rejected applying 1.90% (or 1.67%) and adopted 0.53% as the appropriate corporate guarantee rate, directing recomputation accordingly. A letter of comfort was treated as equivalent to a corporate guarantee and must be benchmarked at 0.53%. Case-Laws Income Tax Mon, 06 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765608