TNMM wrongly rejected as most appropriate method for benchmarking guarantee fee as risk not undertaken

Australia and New Zealand Banking Group Ltd. Vs DCIT (ITAT Mumbai)

ITAT Mumbai held that rejecting Transactional Net Margin Method (TNMM) as the Most Appropriate Method (MAM) for benchmarking guarantee fee is not justifiable since assessee doesn’t undertake any risk of profit or loss on the said transaction.

Facts- Assessee is a commercial bank having its head office in Melbourne, Australia. Australia and New Zealand Banking Group (ANZ) commenced its banking operations in India with the opening of its first branch in Mumbai pursuant to the receipt of the b

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