Corporate guarantee commission to associated enterprises requires arm's length pricing under transfer pricing rules

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....ITAT dismissed assessee's appeal on two grounds. Regarding transfer pricing adjustment on corporate guarantee commission, Tribunal upheld TPO's determination that providing corporate guarantees to associated enterprises constitutes international transactions requiring arm's length pricing. TPO properly applied comparable uncontrolled price method using bank guarantee commission rates with prudent 0.5% downward adjustment for risk differentials. Assessee failed to demonstrate any infirmity in TPO's methodology or comparable selection. On income classification, Tribunal confirmed DRP's ruling that interest on income-tax refund belongs under "Income from Other Sources" rather than business income, as such interest constitutes statutory compensation for delayed refund without nexus to business operations, not arising from commercial activities.....