2024 (1) TMI 1407

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..... aspect and found that the average rate of corporate guarantee commission has been accepted for several decisions of the Tribunal at 0.5% and the assessee in the instant case has already charged a guarantee commission at 0.5% from the associated enterprises. As found on facts that this charge of commission compares favourably with the Bank of Singapore usually charge commission in the range of 0.15 .....

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..... ellate Tribunal, C-Bench, Kolkata (the Tribunal) in ITA No.320/Kol/2021 for the assessment year 2015-16. The revenue has raised the following substantial questions of law for consideration : (a) WHETHER on the facts and in the circumstances of the case the Learned Income Tax Appellate Tribunal was erred in sustaining the order of C.I.T(A), which deleted the transfer pricing adjustment of Rs. 7,71, .....

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..... of corporate guarantee commission has been accepted for several decisions of the Tribunal at 0.5% and the assessee in the instant case has already charged a guarantee commission at 0.5% from the associated enterprises. Further, it was found on facts that this charge of commission compares favourably with the Bank of Singapore usually charge commission in the range of 0.15%. Therefore, it was held .....

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