Dismissing the appeal of the revenue the Court held that ; when no expenditure was incurred for providing guarantee to bank for the loan given to subsidiaries applying the rate of 2.5% by the TPO was held to be not justified . ( AY. 2003 -04 to 2006 -07)
CIT v. Reliance Industries Ltd ( 2018) 161 DTR 420 /( 2019) 410 ITR 468 ( Bom) (HC)Matter remanded to High Court, CIT v. Reliance Industries Ltd ( 2019) 410 ITR 466 /175 DTR 1/ 307 CTR 121 (SC)
S.92C: Transfer pricing – Arm’s Length Price – Corporate guarantee- When no expenditure was incurred for providing guarantee to bank for the loan given to subsidiaries applying the rate of 2.5% by the TPO was held to be not justified .