Corporate and Bank Guarantee’ are ‘International Transaction’ for Transfer Pricing

PCI Limited Vs ACIT (ITAT Delhi) The Assessing Officer made the addition of Rs.73,69,830/-qua Transfer Pricing Adjustment on account of providing corporate guarantee by the Assessee to its overseas associated enterprises companies, namely, PCI Asia Pacific Pvt. Ltd. and PCI Middle East FZE by treating the interest rate of 1.3% based on average fees charged by State Bank of India. The said action of the Assessing Officer was challenged by the Assessee before the ld. Commissioner and it was claimed that ‘corporate guarantee’ is not an ‘international transaction’ as per Section 92 of the ...