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 determination of the arm’s length price (“ALP”) of the inte...