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2023 (2) TMI 1174 - ITAT VISAKHAPATNAMTP adjustment - international transaction - corporate guarantee given by the assessee-company to its AEs for the loan taken by the AEs - HELD THAT:- In the case of M/s. Devi Sea Foods Limited [2022 (9) TMI 587 - ITAT VISAKHAPATNAM] this Bench of the Tribunal has held that the corporate guarantee given to the AE is an international transaction and shall be chargeable @ 0.50% on the amount of corporate guarantee given to the AEs. We are of the considered view that the corporate guarantee commission is an international transaction and should be charged @ 0.50% on the corporate guarantee amount given to the AEs. We therefore partly allowed the grounds raised by the assessee.
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