Transfer Pricing: ITAT Delhi Restricts Corporate Guarantee Fee to 0.30%

Dabur India Ltd Vs ACIT (ITAT Delhi) In this case, the Delhi ITAT examined whether transfer pricing adjustment could be made on account of corporate guarantees issued by the assessee in favour of its associated enterprises in Nepal and Egypt. The TPO had adopted a 4% guarantee commission rate and made an adjustment on the ground that the assessee should have charged service fees for issuing corporate guarantees to its overseas AEs. The CIT(A) partly reduced the adjustment by holding that only 0.50% commission should be charged in respect of the guarantee issued to Dabur Egypt Ltd., while no gu...