3F Industries Ltd. v Asst. CIT (2024) 110 ITR 387 (Visakhapatam) (Trib)

S. 92B : Transfer pricing-International transaction-Arm’s length price-Avoidance of tax–Corporate guarantee-Corporate guarantee commission to be charged qt 0.50 Per Cent.[S.92CA 92E]

Held that the corporate guarantee given to the associated enterprise was an international transaction and should be charged at 0.50 per cent. on the corporate guarantee amount given to the associated enterprises.(AY. 2014-15)

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