https://www.taxtmi.com/caselaws?id=773876 A corporate guarantee to an associated enterprise is treated as an international transaction requiring arm's length benchmarking under the transfer pricing provisions. The transfer pricing adjustment on guarantee commission was upheld because the year-specific arm's length price had to be determined on the facts of the relevant year, and earlier year rates did not control the computation; bank guarantee rates were used as comparables with adjustments for risk and other differences. Interest on income-tax refund was held to be a statutory accretion arising from excess tax payment, lacking proximate nexus with business operations, and was therefore assessable as income from other sources rather than business income. en-us Fri, 30 May 2025 00:00:00 +0530 Mon, 30 Jun 2025 08:43:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773876 A corporate guarantee to an associated enterprise is treated as an international transaction requiring arm's length benchmarking under the transfer pricing provisions. The transfer pricing adjustment on guarantee commission was upheld because the year-specific arm's length price had to be determined on the facts of the relevant year, and earlier year rates did not control the computation; bank guarantee rates were used as comparables with adjustments for risk and other differences. Interest on income-tax refund was held to be a statutory accretion arising from excess tax payment, lacking proximate nexus with business operations, and was therefore assessable as income from other sources rather than business income. Case-Laws Income Tax Fri, 30 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773876