Asst. CIT v. Electrosteel Casting Ltd. (2023)101 ITR 359 (Kol) (Trib)

S. 92C : Transfer pricing-Arm’s length price-Fee for corporate guarantee-0.5%-Specified Domestic Transaction-Transfer of power from eligible units to manufacturing units-Adjustment to be deleted.

The Hon’ble Tribunal held that the arm’s length price of fee for corporate guarantee should be 0.5 per cent. per annum as determined by the Transfer Pricing Officer. Further, the adjustment made by the Transfer Pricing Officer for specified domestic transactions with respect to transfer of power from eligible units of the assessee to its other manufacturing unit was to be deleted. (AY. 2014-15, 2015-16).