Calcutta HC Upholds 0.5% Corporate Guarantee Fee Rate in transfer pricing case

PCIT Vs Karam Chand Thapar And Bros Coal Sales Ltd. (Calcutta High Court) Calcutta High Court has dismissed an appeal filed by the Income Tax Department against Karam Chand Thapar And Bros Coal Sales Ltd., upholding the Income Tax Appellate Tribunal’s (ITAT) decision to delete a transfer pricing adjustment concerning a corporate guarantee commission. The ruling, dated February 28, 2023, for Assessment Year 2015-16, reinforces the acceptance of a 0.5% commission rate for such guarantees. The Revenue had challenged the deletion of a transfer pricing adjustment of Rs. 7,71,77,867/-, arguing...