2018 (12) TMI 608

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..... rate of the bank guarantee at 3% under Section 92CA(3) of the Income Tax Act, 1961 was correct? - Held that:- Question No.1 has been rightly decided by the High Court in favour of the Assessee and against the Revenue. The same would, therefore, not require reopening in this appeal. Interest charged u/s 234B - MAT computation - Whether interest was not payable by the assessee/respondent under .....

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..... evenue. (i) With respect to addition of ₹ 11,51,24,333/- to the income of the assessee (respondent herein) made by the Assessing Officer (A.O.) on account of guarantee commission chargeable to its Associate Enterprises, whether the benchmark fixed by the Transfer Pricing Officer (TPO) for the international transaction by considering arm s length rate of the bank guarantee at 3% under Sect .....

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