The Tribunal held that the Transfer Pricing Officer was to restrict the transfer pricing addition on corporate guarantee to 0.5% of the corporate guarantee. (AY. 2013-14)
United Spirits Ltd v. Dy. CIT (2022)97 ITR 272 (Bang) (Trib)
S. 92C : Transfer pricing-Arm’s length price-Corporate guarantee to associate enterprise-Transfer Pricing adjustment to be restricted to 0.5% of corporate guarantee.