Cadila Pharmaceuticals Ltd. v. ACIT (2024) 115 ITR 51 ((SN)/ 164 taxmann.com 52 (Ahd)(Trib)

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on loans advanced to Associated enterprise uncontrolled price method-Adjustment is deleted-Loan advanced from own funds-Matter remanded to Assessing Officer for re adjudication-Corporate guarantees are International Transactions-Rate of fees to be determined on the basis of guarantee is obtained from a bank-One half Per Cent. considered appropriate on basis of average rates charged by banks. [S.92B]