2022 (6) TMI 1540

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....ASTHY, JM : This appeal by the assessee is directed against the assessment order dated 26/03/2021 passed under section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 [in short 'the Act']. 2. Shri Shekhar Gupta appearing on behalf of the assessee submitted at the outset that he is not pressing ground No. 1 of the appeal. 2.1 In respect of ground No. 2 assailing Transfer Pri....

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....'s own case in preceding assessment years has considered this issue. 4. Both sides heard. The assessee in appeal has raised two grounds. In ground No. l of appeal, the assessee has assailed the findings of Assessing Officer in holding corporate guarantee commission as international transaction. The ld. Authorized Representative of the assessee made a statement at Bar that he is not press....

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....um/2017 (supra). The Co-ordinate Bench upheld the findings of CIT (A) and dismissed the appeal of Revenue. Similarly, in the assessment year 2013-14, the CIT(A) restricted the corporate guarantee commission rate to 0.5%. The Revenue agitated the issue before the Tribunal in ITA No. 5720/Mum/2017(supra). The Tribunal following its earlier order in assessee's own case for assessment year 2....