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Disallowance restricted to 0.5% of guarantee value in corporate guarantee to AE
Case Law Details
- Case Name
- Sundaram Fasteners Limited Vs DCIT (ITAT Chennai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2009-10
- Courts
- All ITAT, ITAT Chennai
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Sundaram Fasteners Limited Vs DCIT (ITAT Chennai)
ITAT Chennai held that the corporate guarantee to Associated Enterprise (AE) is an international transaction and it has to be assessed at 0.5% of the corporate commission. Hence, directed AO to restrict the disallowance at 0.5% of the guarantee value.
Facts- The appeals of assessee is as regards to the TPO/DRP directing the AO to make adjustment to international transactions towards guarantee commission amounting to Rs.14,52,262/- in assessment year 2009-10 and amounting to Rs.20,61,723/- in assessment year 2012-13.
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