2025 (2) TMI 1952

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.... PER OMKARESHWAR CHIDARA (AM) :- The appellant company has filed above cited appeal and the only issue is to be adjudicated is whether arm's length price (ALP for short) determined by the Ld. AO with respect to corporate guarantee given to bank for granting loan to its subsidiary Global Offshore Services BV at rate of 1.4% is correct. The following grounds of appeal are taken by the appellant i....

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....the only issue to be decided in this appeal is whether the ALP or commission to be charged is to be determined at 1.4% as applied by the Ld. AO or 0.25% as charged by the appellant company. 3. In this case, from the A.Y. 2015-16 to 2019-20, the appellant company itself offered commission income @ 0.5%. In the A.Y. 2017-18, the ITAT, Mumbai in appellant's own case has decided that charging the s....

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..... During the hearing proceedings before the Bench, the Ld. AR of the appellant has submitted, in response to a question as to how much percentage was charged in earlier year in similar facts and circumstances, that for A.Y. 2015-16 to 2019-20, it was stated that the company itself charged 0.50% as commission. The Ld. DR has argued that adjustment of ALP @ 1.4% made by the Department should be uphe....