https://www.taxtmi.com/caselaws?id=776928 HC held the Tribunal erred in equating a corporate guarantee with bank guarantees for ALP determination and remanded that issue for fresh consideration, noting reliance on Safe Harbour and failure to apply relevant precedent. The HC sustained the Tribunal's view that deferred payments/receivables fall within transfer pricing scope under amended s.92B, so no interference on interest/TP adjustment for belated receivables. On s.14A disallowance, HC found the Tribunal failed to consider the assessee's audited financials showing ample own funds and directed the assessing authority to justify invocation of s.14A before applying Rule 8D. en-us Thu, 14 Aug 2025 00:00:00 +0530 Mon, 18 Aug 2025 11:59:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776928 HC held the Tribunal erred in equating a corporate guarantee with bank guarantees for ALP determination and remanded that issue for fresh consideration, noting reliance on Safe Harbour and failure to apply relevant precedent. The HC sustained the Tribunal's view that deferred payments/receivables fall within transfer pricing scope under amended s.92B, so no interference on interest/TP adjustment for belated receivables. On s.14A disallowance, HC found the Tribunal failed to consider the assessee's audited financials showing ample own funds and directed the assessing authority to justify invocation of s.14A before applying Rule 8D. Case-Laws Income Tax Thu, 14 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776928