Corporate Guarantees by Assessee Not Subject to Transfer Pricing Adjustments u/s 92B of Income Tax Act.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Transfer pricing adjustment - issuance of corporate guarantees were in the nature of shareholder activities- as was the uncontroverted claim of the assessee, and, as such, could not be included in the ‘provision for services’ under the definition of ‘international transaction’ u/s 92B - AT....