Dismissing the appeal of the revenue the Court held that Arm’s length price of corporate guarantee cannot be determined on the basis of bank guarantee- Adjustment of 3% of the amount of guarantee given by the assessee is held to be not justified (Followed ITA No. 1302 of 2014 dt 2-2-2017)( AY.2009-10)
CIT v. Glenmark Pharmaceuticals Ltd. (2019) 417 ITR 479/ 260 Taxman 249 (Bom.)(HC) Editorial: SLP of revenue is dismissed CIT v. Glenmark Pharmaceuticals Ltd ( 2019) 416 ITR 138 (St)
S. 92C : Transfer pricing–Arm’s length price-Corporate guarantee- Arm’s length price of corporate guarantee cannot be determined on the basis of bank guarantee- Adjustment of 3% of the amount of guarantee given by the assessee is held to be not justified.