Held that considering the fact that it was a corporate guarantee for which no fees was paid by the assessee, the transfer pricing adjustments were estimated against these transactions at 0.20 per cent. the Transfer Pricing Officer was to recompute the arm’s length of the guarantee commission at 0.20 per cent.(AY.2011
Dy. CIT v. KEC International Ltd. (2021) 87 ITR 587 (Mum.)(Trib.)
S. 92B : Transfer pricing-Associated enterprise-Performance guarantee-International Transactions-Transfer Pricing Adjustment-Performance Guarantee-No risk was involved-Adjustment is not justified-Corporate Guarantee to bank on behalf of Associated enterprise-Directed to recompute arm’s length price of guarantee commission at 0.20 Per Cent.