https://www.taxtmi.com/caselaws?id=790878 Transfer pricing for a back-to-back guarantee arrangement had to reflect the branch's limited support functions and absence of real entrepreneurial risk, so benchmarking under TNMM was accepted and CUP-based bank guarantee comparables were rejected, eliminating the adjustment. Marketing support services for derivative products also could not be adjusted on a Profit Split Method basis where aggregation of positive and negative deal outcomes showed no surviving transfer pricing adjustment. Reimbursement of telecommunication and expatriate employee costs was held to be direct branch-specific expenditure outside section 44C and deductible under section 37(1). Interest remitted by the India branch to its head office and overseas branches was not taxable in India under Article 11, applying the receipt-from-self principle. en-us Thu, 12 Feb 2026 00:00:00 +0530 Sat, 02 May 2026 07:40:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790878 Transfer pricing for a back-to-back guarantee arrangement had to reflect the branch's limited support functions and absence of real entrepreneurial risk, so benchmarking under TNMM was accepted and CUP-based bank guarantee comparables were rejected, eliminating the adjustment. Marketing support services for derivative products also could not be adjusted on a Profit Split Method basis where aggregation of positive and negative deal outcomes showed no surviving transfer pricing adjustment. Reimbursement of telecommunication and expatriate employee costs was held to be direct branch-specific expenditure outside section 44C and deductible under section 37(1). Interest remitted by the India branch to its head office and overseas branches was not taxable in India under Article 11, applying the receipt-from-self principle. Case-Laws Income Tax Thu, 12 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790878