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| The Tax Publishers2019 TaxPub(DT) 2485 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
Assessee had been charged a rate of 0.9% by an Indian Bank for SBLC. It was a clear case of internal CUP and accordingly, TPO was directed to restrict addition on account of corporate guarantee fee @ 0.9%.
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Transfer pricing - Determination of ALP - Corporate guarantee fees to be charged form AE -
Assessee extended corporate guarantee in favour of its AE abroad, however, without charging any corporate guarantee fee. TPO suggested TP adjustment considering 3% corporate guarantee fee as at arm's length.Held: Assessee had been charged a rate of 0.9% by an Indian Bank for SBLC. It was a clear case of internal CUP and accordingly, TPO was directed to restrict addition on account of corporate guarantee fee @ 0.9%.
REFERRED :
FAVOUR : Partly in assesse's favour.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 92C
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