https://www.taxtmi.com/caselaws?id=468346 Debenture-related upfront and legal fees already fully claimed and allowed in an earlier year could not be allowed again in the year under consideration, as that would result in double deduction. Corporate guarantee commission under transfer pricing could not be benchmarked by simply applying bank guarantee rates; the transaction had to be tested on its own facts, and the net adjustment was worked out as nil in the giving-effect proceedings. For standby letter of credit, the transfer pricing adjustment was confined to the portion of commission cost not recovered from the associated enterprise, since only the unrecovered amount remained an expense borne by the assessee. en-us Fri, 28 Nov 2025 00:00:00 +0530 Wed, 29 Apr 2026 18:58:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468346 Debenture-related upfront and legal fees already fully claimed and allowed in an earlier year could not be allowed again in the year under consideration, as that would result in double deduction. Corporate guarantee commission under transfer pricing could not be benchmarked by simply applying bank guarantee rates; the transaction had to be tested on its own facts, and the net adjustment was worked out as nil in the giving-effect proceedings. For standby letter of credit, the transfer pricing adjustment was confined to the portion of commission cost not recovered from the associated enterprise, since only the unrecovered amount remained an expense borne by the assessee. Case-Laws Income Tax Fri, 28 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468346