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Income Tax - Highlights / Catch Notes

Home Highlights December 2023 Year 2023 This

TP adjustment commission on letter of credit - international ...

Case Laws     Income Tax

December 21, 2023

TP adjustment commission on letter of credit - international transaction or not? - CIT (A) appreciated the difference between corporate guarantee and Letter of Comfort. AR further submits that there is a basic difference between corporate guarantee and Letter of Comfort. In a Letter of Comfort, the party issues only a letter that a subsidiary or group company would comply term of financial transaction and have no obligation to indemnify, however, in case of corporate guarantee, the party issuing guarantee is under obligation to the lender. - No additions - AT

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