https://www.taxtmi.com/caselaws?id=791941 Arm's length guarantee commission on a corporate guarantee jointly extended with a subsidiary was rightly restricted to 0.25% in the assessee's hands, because the transfer pricing rate of 0.5% was found to reflect equal sharing of the guarantee risk between both guarantors. Proportionate interest on borrowings was also not disallowable in respect of loans advanced to group entities, as the advances were made in the course of the assessee's real estate business for commercial expediency, including project needs, group financial stress, litigation, and delay. The absence of interest income from those advances did not by itself justify disallowance. The appellate relief on both issues was sustained. en-us Mon, 18 May 2026 00:00:00 +0530 Wed, 20 May 2026 08:31:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791941 Arm's length guarantee commission on a corporate guarantee jointly extended with a subsidiary was rightly restricted to 0.25% in the assessee's hands, because the transfer pricing rate of 0.5% was found to reflect equal sharing of the guarantee risk between both guarantors. Proportionate interest on borrowings was also not disallowable in respect of loans advanced to group entities, as the advances were made in the course of the assessee's real estate business for commercial expediency, including project needs, group financial stress, litigation, and delay. The absence of interest income from those advances did not by itself justify disallowance. The appellate relief on both issues was sustained. Case-Laws Income Tax Mon, 18 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791941