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2021 (4) TMI 1321 - AT - Income TaxTP Adjustment - International transaction - ALP of corporate guarantee commission - A.O./TPO’s action in holding that there was international transaction insofar as bank guarantee is concerned and assuming the said value at 2% of guarantee value - HELD THAT:- AR has not disputed the fact that corporate guarantee commission is an international transaction. The AR only disputes 2% attributed for imputing ALP of corporate guarantee commission. On identical facts in the case of Manipal Global Education Services Pvt. Ltd[2019 (5) TMI 1942 - ITAT BANGALORE] had imputed 0.50% as cost, instead of 2% arrived by the TPO. The TPO in the cited case also arrived at 2% by taking the credit rating of the tax payer just like this case. Thus we direct the AO/TPO to make TP adjustment in respect of corporate guarantee at 0.50% for the assessment years under consideration. It is ordered accordingly.
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