Tribunal Allows 0.5% Rate for Corporate Guarantee Commission and Directs Fresh AMP Expense Examination in Transfer Pricing Case

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....The ITAT partially allowed the assessee's appeal regarding transfer pricing adjustment for corporate guarantee, directing AO to adopt guarantee commission at 0.5% instead of 2%. On AMP expenses, the matter was remanded for fresh examination to determine existence of international transaction. The Tribunal confirmed TP adjustment for royalty income, finding the deferment was an afterthought to postpone tax liability. Disallowance under SS14A was partly allowed, directing recalculation under Rule 8D(2)(iii) based only on dividend-yielding investments. Export agency commission was held not subject to TDS as it didn't constitute technical services. The Tribunal allowed deduction of amortized premium on forward contracts and foreign exchange loss on ECB repayment. Additional depreciation claim on assets put to use in previous year was also allowed.....