Held that the provision of corporate guarantee constitutes an international transaction. As the Transfer Pricing Officer had rejected the combined benchmarking analysis conducted by the assessee and did not consider the transaction as an international transaction, as claimed by the assessee, and benchmarked it accordingly, the matter had to be remanded to the Transfer Pricing Officer only to benchmark the transaction of payment for corporate guarantee fees as an international transaction.(AY.2013-14)
Peri (India) Pvt. Ltd. v. Dy. CIT (2022)95 ITR 3 (SN)(Mum) (Trib)
S. 92C : Transfer pricing-Arm’s length price-Corporate guarantee-Matter remanded [S.92B]