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    <title>2025 (9) TMI 568 - ITAT CHENNAI</title>
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    <description>Corporate guarantee issued to associated enterprises is treated as an international transaction under section 92B, and the benchmark commission was applied at 0.5% rather than 0.2%, as the bank rate relied on by the assessee was not accepted as the proper comparables-based measure. Depreciation and maintenance expenditure on the aircraft was allowed as business expenditure because the aircraft was found to have been used for business purposes, supported by log books and movement sheets already before the assessing authority, so the Rule 46A objection did not survive. The transfer pricing adjustment was therefore modified, while the aircraft-related expenditure relief was maintained.</description>
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      <title>2025 (9) TMI 568 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=778079</link>
      <description>Corporate guarantee issued to associated enterprises is treated as an international transaction under section 92B, and the benchmark commission was applied at 0.5% rather than 0.2%, as the bank rate relied on by the assessee was not accepted as the proper comparables-based measure. Depreciation and maintenance expenditure on the aircraft was allowed as business expenditure because the aircraft was found to have been used for business purposes, supported by log books and movement sheets already before the assessing authority, so the Rule 46A objection did not survive. The transfer pricing adjustment was therefore modified, while the aircraft-related expenditure relief was maintained.</description>
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