Benchmarking corporate guarantee fees based on bank guarantee rates is incorrect

Crayon Group Vs ACIT (ITAT Mumbai)

ITAT Mumbai held that the bank guarantee rates cannot be considered for benchmarking corporate guarantee fees, therefore benchmarking of AO and DRP is also incorrect. It depends on creditworthiness of parties and benefit arising out of the same in the hands of the parties to the transaction.

Facts- The assessee is a foreign company incorporated in Norway engaged in the business of distribution of software licenses across various types of

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