ITAT Quashes ₹16.48 Cr TP Adjustment on Negative Lien vs. Guarantee

JOGPL Pvt. Ltd Vs DCIT (ITAT Delhi) ITAT: Holds negative lien, on receivables and participating interest on oil-&-gas blocks, not corporate guarantee Facts: JOGPL Pvt. Ltd. (“the assessee”) is an Indian company engaged in oil and gas exploration and production. It is a wholly owned subsidiary of JEE Energy Ventures Pvt. Ltd. (“JEEVPL”), a holding company that, along with its group entities, is engaged in a wide range of energy and natural resources businesses across India and abroad. During the relevant assessment year (AY 2017–18), two of the assessee’s associated enterprises...