https://www.taxtmi.com/caselaws?id=462560 Corporate guarantee to an associated enterprise falls within the scope of an international transaction after the statutory amendment to section 92B, and its arm's length commission may be benchmarked at 0.5% on the facts accepted by the Tribunal. Inter-unit transfer of tea leaves was held not to warrant adjustment where the assessee's annual weighted average price method was consistent and more reliable than selective monthly averaging. Interest on USD-denominated loans to an associated enterprise required benchmarking by reference to USD LIBOR, and the peak-balance domestic spread approach was rejected; no transfer pricing adjustment was therefore called for. The Revenue's appeal failed on all three issues. en-us Fri, 07 Jul 2023 00:00:00 +0530 Tue, 01 Jul 2025 19:08:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462560 Corporate guarantee to an associated enterprise falls within the scope of an international transaction after the statutory amendment to section 92B, and its arm's length commission may be benchmarked at 0.5% on the facts accepted by the Tribunal. Inter-unit transfer of tea leaves was held not to warrant adjustment where the assessee's annual weighted average price method was consistent and more reliable than selective monthly averaging. Interest on USD-denominated loans to an associated enterprise required benchmarking by reference to USD LIBOR, and the peak-balance domestic spread approach was rejected; no transfer pricing adjustment was therefore called for. The Revenue's appeal failed on all three issues. Case-Laws Income Tax Fri, 07 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462560