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2023 (8) TMI 209 - AT - Income TaxTP Adjustment - corporate guarantee given by the assessee company to its AEs - international transaction or not? - HED THAT:- We have also gone through the decision of this Tribunal in the assessee’s own case for the AY 2014-15 [2023 (2) TMI 1174 - ITAT VISAKHAPATNAM] wherein the Tribunal, after analyzing the issues at length, held that the corporate guarantee commission is an international transaction and should be charged @ 0.50% on the corporate guarantee amount given to the AEs. Thus we hereby hold that the corporate guarantee commission is an international transaction and should be charged @ 0.50% on the corporate guarantee amount given to the AEs. Decided in favour of assessee partly.
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