Transfer Pricing Adjustment - Arm's Length Adjustment to Income ...
Tribunal Orders Reassessment of Transfer Pricing for Guarantee Commission and Loan Interest with Proper Benchmarking.
March 26, 2024
Case Laws Income Tax AT
Transfer Pricing Adjustment - Arm's Length Adjustment to Income from Guarantee Commission - Income from Interest on Loans Advanced to Associated Enterprise - The Tribunal emphasized the need for proper benchmarking in determining the arm's length price for these transactions, directing remands to the Assessing Officer and Commissioner for reevaluation. Overall, the appeals were allowed for statistical purposes, with the Tribunal providing detailed instructions for reassessment based on appropriate benchmarks.
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