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1. TPA - ALP - the 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 on international transaction involving payment of guarantee fees to associated enterprise was held unjustified. Assessee demonstrated...

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

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

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. 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...

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

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

12. Transfer price adjustment - Bank guarantee commission - There was a clear benefit accrued to the Associated Enterprises by the guarantee provided by the assessee and...

13. TP Adjustment - where the Tribunal has accepted the international transaction to be at Arm’s Length Price in the hands of AE, then the international transaction that the...

14. Transfer pricing addition on account of Corporate guarantee - performance guarantees in the instant case are a specie of the genus of corporate guarantee and cannot be...

15. 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...