TP Adjustment - assessee has issued the corporate guarantee on ...

ITAT Rules Favorably on Corporate Guarantee and Brand Royalty in Transfer Pricing Dispute.

March 21, 2024

Case Laws     Income Tax     AT

TP Adjustment - assessee has issued the corporate guarantee on behalf of AE’s - interest saved approach - The ITAT decided in favor of the assessee, directing the AO to restrict the addition by splitting the interest benefit on a 50:50 basis between the guarantor and the borrower. It was noted that earlier years' tribunals had accepted a splitting of the interest savings as a reasonable approach. - With regard to Royalty, the ITAT allowed the assessee's grounds concerning TP adjustments related to the charge of brand royalty, following earlier tribunal decisions that set specific rates for such royalties.

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