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1. TPA - corporate guarantee commission fee which is to be recovered from AE should be @ 0.50% which would meet the arms length requirement. - AT

2. TP Adjustment - Addition on account of corporate guarantee - International transaction - guarantee fees / commission @ 0.35% will meet the arm’s length criteria in the...

3. TP Adjustment to the licence fees paid for time and billing software - Determination of arm's length price at Nil in grounds 1 & 2 and at Rs. 50 lakhs on ad hoc basis in...

4. TP Adjustment - Arm's length price of the corporate guarantee fee - Lower authorities have also included a letter of comfort as part of corporate guarantee - We reject...

5. Transfer pricing adjustment – Guarantee charges for guarantee to AE – no upward adjustment in the ALP in relation to charging of guarantee commission over and above...

6. Transfer pricing adjustment on international transaction involving payment of guarantee fees to associated enterprise was held unjustified. Assessee demonstrated...

7. Demand of service tax - providing services without consideration (free) to its associate companies - activity of giving corporate guarantee - The Show Cause Notice...

8. Corporate guarantee - fee for technical services (FTS) under article 13 of the India France DTAA and section 9(1)(vii) - services of corporate guarantee by the assessee...

9. Transfer pricing adjustment towards notional guarantee commission chargeable for the guarantee extended to its associated enterprises - commission chargeable for...

10. TP Adjustment - arm’s length price of interest on short term loan granted to the AE - The fact that the assessee has provided a short term loan only for a period of 15...

11. TPA - ALP determination - Without complying to the statutory provisions, the Transfer Pricing Officer certainly cannot determine the arm's length price on ad-hoc /...

12. TP Adjustment - valuation of Arms Length Price (ALP) - No Arm's Length Price is required to be determined for a transaction with specified persons in section 40A(2)(b)...

13. Arm Length Price (ALP) - Interest free loans to the sister concern by the Assessee-company - AE's who are 100% subsidiaries - The appropriate rate would be LIBOR plus 2% - AT

14. TP Adjustment - ‘receipt of counter guarantee commission - providing counter guarantee at the instance of its overseas AE - TPA made in the impugned assessment order...

15. TPA - even if it could be treated as a corporate guarantee for benchmarking purposes, the corporate guarantee does not constitute an international transaction under...