The ITAT, an Appellate Tribunal, addressed several key issues in the case. Firstly, a short grant of...

The ITAT, an Appellate Tribunal, addressed several key issues in the case. Firstly, a short grant of advance tax credit was challenged, leading to a decision to send the matter back to the ld. AO for verification. Secondly, a TP adjustment related to a corporate guarantee was deemed an international transaction under Section 92B. This decision was supported by a relevant court judgment. Finally, the calculation of the corporate guarantee fee was discussed, with a range of 0.2% to 0.5% considered justified based on precedent. The TPO was directed to compute the fee at 0.5% and delete any excess amount added to the assessee's income. Overall, the Tribunal partly allowed the assessee's grounds on these matters. .....

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