INCOME TAX ACT, 1961

Section 92C

Transfer pricing - Computation of ALP - Adjustment for corporate guarantee fee -

Revenue challenged the order of Tribunal allowing the appeal of assessee holding that Arm's length price of corporate guarantee could not be determined on the basis of bank guarantee by following its earlier order.Held:- Appeal could not be maintained, as no substantial question of law arose for consideration, where Tribunal had followed its own order in respect of same assessee in earlier assessment year and no distinguishing feature in fact or in law was indicated by Revenue in the present appeal.

REFERRED :

FAVOUR : In assessee's favour

A.Y. : 2009-10

Income Tax Act, 1961

Section 80-IC

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