HC upholds Interest Rate on Corporate Guarantee to 0.5% Under Section 92C

PCIT Vs Manugraph India  Ltd. (Bombay High Court) Bombay High Court has dismissed an appeal filed by the Principal Commissioner of Income Tax (PCIT) against Manugraph India Ltd. for the Assessment Year 2008-09. The appeal concerned two questions of law related to transfer pricing adjustments: the interest rate on loans provided by Manugraph to its Associated Enterprise (AE) and the commission rate for a corporate guarantee extended to the AE. The Income Tax Appellate Tribunal had restricted the interest rate on loans to ‘LIBOR + 2%’ (from 17.26% proposed by the TPO) and the corpo...