ALP of guarantee commission determined @0.3523% instead of 1.25%

DCIT (Central Circle) Vs Macrotech Developers Limited (ITAT Mumbai) ITAT Mumbai held that Arm’s Length Price (ALP) of guarantee commission was determined at the rate of 0.3523% instead of 1.25%. Facts- The assessee is engaged in the business of real estate, construction. AO during the course of assessment noticed that there are specified domestic transactions and also international transactions in the nature of guarantee. Accordingly, AO made a reference to the Transfer Pricing Officer (TPO) for determination of arm’s length price. The TPO passed an order u/s. 92CA(3) determining the total...