The Tribunal held that it was not clear from where and how the Transfer Pricing Officer had figured out that the assessee had issued corporate guarantee for its associated enterprise. The addition made was arbitrary, not backed by any evidence Therefore, Additions deleted by CIT (A) justified. (AY. 2014-15)
ACIT v. Manaksia Ltd. (2022)97 ITR 433 (Kol) (Trib)
S. 92C : Transfer pricing-Arm’s length price-Fee for Corporate guarantee from associated enterprise-Source of TPO for figuring out that assessee issued corporate guarantee not clear-Additions deleted by CIT (A) is justified. [S.92CA]