Guarantee fee to AE resulted into reduced interest rate hence TP adjustment unjustified: ITAT Ahmedabad

Bosch Rexroth (India) Ltd Vs ITO (ITAT Ahmedabad) ITAT Ahmedabad held that benefit demonstrated in form of reduced interest rate on account of guarantee, thus, payment of guarantee fee justifiable. Accordingly, TP adjustment on account of the guarantee fee payment to AE deleted. Facts- The assessee has availed Rs.100 crores borrowing from its group company and interest charged thereon was at rate of 11%. For the said purpose, one of the AEs of the assessee acted as guarantor and charged guarantee fee at the rate of 0.75% per annum. During the impugned year, the assessee paid guarantee charges ...