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1. Transfer pricing addition on account of Corporate guarantee - performance guarantees in the instant case are a specie of the genus of corporate guarantee and cannot be...

2. TPA - even if it could be treated as a corporate guarantee for benchmarking purposes, the corporate guarantee does not constitute an international transaction under...

3. Corporate Guarantee or Letter of Comfort given by the assessee to its Associate Enterprise does not involve any cost to the assessee, therefore, it was outside the ambit...

4. TP Adjustment - corporate guarantee given by the assessee company to its AEs - the corporate guarantee commission is an international transaction and should be charged @...

5. Preferential transactions or not - Corporate Guarantees - the transaction covered under the Corporate Guarantees would not come within the parameters of the preferential...

6. Demand of service tax - providing services without consideration (free) to its associate companies - activity of giving corporate guarantee - The Show Cause Notice...

7. TP Adjustment - corporate guarantee - international transaction of not? - the issue of corporate guarantee were in the nature of share holder activity and the same could...

8. TP adjustment commission on letter of credit - international transaction or not? - CIT (A) appreciated the difference between corporate guarantee and Letter of Comfort....

9. Invocation of performance guarantee - CIRP proceedings - the Adjudicating Authority passed the Order that “the performance guarantee given by the bankers on behalf of...

10. TP Adjustment - Arm's length price of the corporate guarantee fee - Lower authorities have also included a letter of comfort as part of corporate guarantee - We reject...

11. TP Adjustment - ALP - transaction on corporate guarantee - When the guarantee has been given by two concerns and on similar terms and conditions arising out of the same...

12. Corporate guarantee - fee for technical services (FTS) under article 13 of the India France DTAA and section 9(1)(vii) - services of corporate guarantee by the assessee...

13. Liquidation Proceedings - Invocation of Bank Guarantee - there is no material to show that any fraud was played by the Corporate Debtor in obtaining Bank Guarantee from...

14. TPA - where the variation between the arm’s length price determined u/s 92C and the price at which the international transaction or specified domestic transaction has...

15. TP Adjustment - Issuance of the corporate guarantee in favor of subsidiary - To be treated as a shareholders' activity or not - non-charging of corporate guarantee...