Tribunal held that corporate guarantee given by assessee on behalf of its Associated Enterprises was an international transaction under section 92B of the Act. On appeal the assessee contended that provision of corporate guarantee to Associated Enterprises was in nature of shareholder service for which arm’s length compensation was not required. High Court admitted the appeal on substantial question of law.
Je Energy Ventures (P) Ltd. v. Dy. CIT (2022) 284 Taxman 634 (All.)(HC)
S. 92B : Transfer pricing-International transaction-Corporate guarantee-Substantial question of law admitted by High Court. [S. 92C, 260A]