Letters of Comfort will construe as an International Transaction u/s 92B

Asian Paints Ltd. Vs ACIT (ITAT Mumbai)

Conclusion: Issuance Of Letters Of Comfort/Support will Construe As International Transaction U/s 92B considering corporate guarantee issued by assessee could not be compared with the letters of comfort and therefore agreed with the computation of arm’s length rate of 0.04%.

Held:  Assessee-company was engaged in the business of manufacturing paints and enamels. During the assessment proceedings, AO made reference under section 92CA(1) to the Transfer Pricing Officer (“TPO”) for the det

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