ALP determinable for international transaction of Corporate Guarantee

Sami – Sabinsa Group Ltd. Vs DCIT (ITAT Bangalore) Facts- The assessee is an Indian multinational company engaged in the export of standardized herbal extracts, fine chemicals, specialty chemicals, cosmeceuticals, phytonutrients and probiotics. The assessee has modern state-of -the art manufacturing facilities in and around Bengaluru and Hyderabad. In this appeal, the first issue that has to be adjudicated is with regard to the determination of Arm’s Length Price in respect of international transaction of sale of herbal products by the assessee to its Associated Enterprise (AE), as require...