2022 (9) TMI 1455

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....hajan ORDER Heard Sri Divyanshu Agrawal and Sri Suyash Agarwal, learned Advocates for the appellant and Sri Gaurav Mahajan, learned counsel for the Income Tax Department. In this Income Tax Appeal under Section 260A of the Income Tax Act, 1961, the substantial questions of law which have been framed for admission of appeal, are as under:- "a) Whether or not the ITAT was legally correct in hol....

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....ted Enterprises, as an international transaction under Section 92B of the Act disregarding the fact that the provision of corporate guarantee to the AEs was in the nature of shareholder activity for which arm's length compensation is not required." The Tribunal has noted that the issue relates to deletion of addition of Transfer Pricing Adjustment made to Arm's Length Price(ALP) of corpor....