Rosy Blue (India) (P.) Ltd. v. DCIT (2021) 188 ITD 909 (Mum.) (Trib.)

S. 92C : Transfer pricing-Arm’s length price-Interest free loan to Associated enterprises-Libor rate is to be applied-Corporate guarantee-Guarantee commission/fee to be charged at 0.5 per cent. [S. 92B]

Held that arm’s length interest would be determined by applying LIBOR rate.  Providing corporate guarantee to a bank by assessee on behalf of its AE was an international transaction; guarantee commission/fee to be charged at 0.5 per cent. (AY. 2014 15)