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Case Law Details

Case Name : MUFG Bank Ltd. Vs ACIT (ITAT Delhi)
Related Assessment Year : 2012-13
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MUFG Bank Ltd. Vs ACIT (ITAT Delhi)

ITAT Delhi held that counter guarantee with negligible risks can not per se be compared with guarantee offered by independent parties/ banks shouldering very high risk parameters as also observed by the co-ordinate bench in other assessment years.

Facts- The assessee is a foreign company incorporated under the laws of Japan and is a tax resident of Japan. The assessee operates its banking business in India under the license from RBI and is primarily engaged in whole

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