https://www.taxtmi.com/caselaws?id=774299 The ITAT Visakhapatnam dismissed Revenue's appeal on three transfer pricing issues. First, corporate guarantee provided to Associated Enterprise without expenditure incurred by assessee was held not to constitute international transaction under section 92B. Second, regarding instant coffee pricing differences between AE and non-AE transactions, the Tribunal upheld CIT(A)'s deletion of adjustment, finding TPO erred by considering only two product sizes instead of all eleven sizes when assessee demonstrated no profit shifting. Third, on interest on receivables, the Tribunal confirmed CIT(A)'s deletion of proposed interest adjustment on delayed receipts from AEs, noting transactions were at arm's length price and no undue advantage was established by department. en-us Tue, 10 Jun 2025 00:00:00 +0530 Mon, 07 Jul 2025 08:42:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774299 The ITAT Visakhapatnam dismissed Revenue's appeal on three transfer pricing issues. First, corporate guarantee provided to Associated Enterprise without expenditure incurred by assessee was held not to constitute international transaction under section 92B. Second, regarding instant coffee pricing differences between AE and non-AE transactions, the Tribunal upheld CIT(A)'s deletion of adjustment, finding TPO erred by considering only two product sizes instead of all eleven sizes when assessee demonstrated no profit shifting. Third, on interest on receivables, the Tribunal confirmed CIT(A)'s deletion of proposed interest adjustment on delayed receipts from AEs, noting transactions were at arm's length price and no undue advantage was established by department. Case-Laws Income Tax Tue, 10 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774299