Corporate guarantee for supplies to AE in Singapore Falls under TP

Inflow Technologies Private Limited Vs ACIT (ITAT Bangalore) The assessee, as a part of share purchase agreement, during the business structuring had given a corporate guarantee to one of its group supplier CISCO for supplies made to its AE (Inflow Singapore). According to the assessee, it did not intend to get any remuneration for the same since these activities were in the nature of shareholders / stewardship activities, and was only incidental to the main activities of the assessee. It was further submitted that it had not costed anything to the assessee in making such an arrangement. It wa...