Disallowance restricted to 0.5% of guarantee value in corporate guarantee to AE

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

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