https://www.taxtmi.com/highlights?id=97751 Transfer pricing dispute over benchmarking of a guarantee commission: the article explains that the tax authority applied an ad hoc upward adjustment using a CUP-based market rate, but a tribunal relied on earlier coordinate-bench analysis that the combined guarantee fee approximated 0.69% and the assessee's allocated share (about 57%) reflected limited functions, absence of independent risk-bearing, and a back-to-back counter guarantee; applying that reasoning the tribunal found the TPO/DRP ad hoc rate untenable and deleted the upward transfer pricing adjustment to the guarantee commission for the year under review. en-us Mon, 16 Mar 2026 08:42:22 +0530 Mon, 16 Mar 2026 08:42:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=97751 Transfer pricing dispute over benchmarking of a guarantee commission: the article explains that the tax authority applied an ad hoc upward adjustment using a CUP-based market rate, but a tribunal relied on earlier coordinate-bench analysis that the combined guarantee fee approximated 0.69% and the assessee's allocated share (about 57%) reflected limited functions, absence of independent risk-bearing, and a back-to-back counter guarantee; applying that reasoning the tribunal found the TPO/DRP ad hoc rate untenable and deleted the upward transfer pricing adjustment to the guarantee commission for the year under review. Highlights Income Tax Mon, 16 Mar 2026 08:42:22 +0530 https://www.taxtmi.com/highlights?id=97751