2018 (5) TMI 1811

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..... y of credit facility and therefore, the same was required to be compensated by its AE. Our view is duly supported by the decision of this Tribunal rendered in Everest Kanto Cylinders Ltd. Vs. DCIT [2012 (11) TMI 1099 - ITAT MUMBAI] as affirmed by Hon’ble Bombay High Court [2015 (5) TMI 395 - BOMBAY HIGH COURT]wherein the rate of commission has been adopted @0.5%. Respectfully, following the same, .....

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..... nterprises [AE]. The assessment for impugned AY was framed by Ld. Assistant Commissioner of Income Tax, Central Circle-34 on 21/03/2013 u/s 143(3) read with section 144C of the Income Tax Act, 1961 wherein the assessee has been saddled with TP adjustment of ₹ 1,66,20,644/- against corporate guarantee as proposed by Ld. Transfer Pricing Officer [TPO] u/s 92CA(3). 2. Facts in brief, qua the .....

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..... pugned order dated 12/11/2014, wherein the stand of the Lower authorities has been confirmed. Aggrieved, the assessee is in further appeal before us. 3. The Ld. Authorized Representative for assessee [AR] placing reliance on various decisions of the Tribunal submitted that corporate guarantee was not an international transaction within the meaning of Section 92B and therefore, no adjustment the .....

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