2018 (6) TMI 1619

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.... on 23.11.2012 declaring an income of Rs. 735,61,83,830/- which was revised to Rs. 735,90,74,570/- on 31.03.2014. The case of the assessee was selected for scrutiny. During the course of assessment proceeding the AO noticed that the assessee has entered into international transactions with its AEs (associated enterprises) and therefore a reference was made under section 92CA(1) of the Act dated 17.12.2014 to Transfer Pricing Officer. The assessee is in the business of broadcasting of satellite television channels, space selling agent for other television channels, sale of television programmes, films, movies etc. The AO finally framed the assessment under section 143(3) read with section 144C (13) of the Act by making two additions i.e. one....

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....ch of the Tribunal in assessee's own case in ITA No.2035/M/2016 for A.Y. 2011-12 vide order dated 28.05.18 wherein it has been held that guarantee commission should be worked out at 0.50% of the average amount of the loan outstanding. The operative part of the decision is reproduced as under: "9. We have heard rival contentions and perused the record. We noticed that the Coordinate Bench of the Tribunal has considered the issue relating to giving of corporate guarantee in the assessee's own case and has held that guarantee commission should be worked out at 0.50% of the average amount of loan outstanding. Before us, the assessee has argued that the corporate guarantee given by the assessee should not be considered to be an internatio....