https://www.taxtmi.com/caselaws?id=788038 Whether an upward transfer pricing adjustment to guarantee commission is sustainable turned on functional and risk analysis and applicability of a coordinate-bench precedent; the assessee had reissued a counter guarantee, performed limited processing functions with risks and costs back to back with the associated enterprise, and allocated a combined commission. Applying accepted transfer pricing principles (use of contemporaneous comparables and CUP methodology) and giving effect to the earlier identical reasoned decision, the ITAT set aside the ALP adjustment and allowed the assessee's ground, deleting the upward adjustment. en-us Tue, 10 Mar 2026 00:00:00 +0530 Mon, 16 Mar 2026 08:42:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788038 Whether an upward transfer pricing adjustment to guarantee commission is sustainable turned on functional and risk analysis and applicability of a coordinate-bench precedent; the assessee had reissued a counter guarantee, performed limited processing functions with risks and costs back to back with the associated enterprise, and allocated a combined commission. Applying accepted transfer pricing principles (use of contemporaneous comparables and CUP methodology) and giving effect to the earlier identical reasoned decision, the ITAT set aside the ALP adjustment and allowed the assessee's ground, deleting the upward adjustment. Case-Laws Income Tax Tue, 10 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788038