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TMI Blog2022 (9) TMI 1455X X X X Extracts X X X X X X X X Extracts X X X X ..... ing that the corporate guarantee provided by the appellant to banks for providing loan to its AE without charging any fee or commission, is an international transaction under Section 92B when the transaction is of such a nature as to have no bearing on profits, income, losses or assets of enterprise? HELD THAT:- While TPO, treating the corporate guarantee as an international transaction, charge ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the above fact, decided to remit the issue to the Assessing Officer for deciding afresh with similar direction. As the substantial questions of law framed herein relates to the same issue, the Assessing Officer would decide the fate. No substantial questions of law. - Hon'ble Mrs. Sunita Agarwal And Hon'ble Vipin Chandra Dixit For the Appellant : Suyash Agarwal For the Resp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the ITAT was legally correct in holding that, the Explanation to Section 92B of the Income Tax Act, 1961 inserted in the statute vide Finance Act, 2012, enhancing the scope of an anti-avoidance provision, can be implemented with retrospective effect and made applicable to Assessment Year 2011-12? c) Whether or not the ITAT was legally correct in treating the corporate guarantee provided by appe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t year 2009-10 and 2010-11 came up for consideration before the Tribunal and while deciding the assessment, the matter has been remitted to the Assessing Officer for de-novo adjudication after due and reasonable opportunity of hearing to the assessee. The issue referred for reconsideration has been made in the light of the observation of the Commissioner(Appeals) and it was noticed that the Commis ..... X X X X Extracts X X X X X X X X Extracts X X X X
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