ALP of corporate guarantee cannot be determined by comparing with bank guarantee

CIT Vs M/s. Glenmark Pharmaceuticals Ltd. (Supreme Court of India) Hon;ble Supreme Court Upheld the Judgment of Hon;ble HIgh Court and held that Arm’s length price of corporate guarantee could not be determined on the basis of comparison with bank guarantee and as such, High Court rightly affirmed the view taken by ITAT deleting the addition to the income of assessee – company made by AO on account of guarantee commission chargeable to its AE. FULL TEXT OF THE SUPREME COURT JUDGMENT The following two questions arise for determination in this appeal filed by the Revenue. (i) With respec...