Where the TPO made an adjustment for guarantee commission without giving any reasons, the Tribunal was justified in restricting the adjustment.
CIT, (LTU) v. Reliance Industries Ltd. [2024] 161 taxmann.com 423 (Bom.)(HC)
S. 92C : Transfer pricing-Arm’s length price-Corporate guarantee-Adjustment made without giving reasons is unsustainable-Order of Tribunal affirmed.[S. 260A]
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