Transfer pricing adjustment on account of alleged guarantee transaction

Bennett Coleman & Co Ltd Vs DCIT (ITAT Mumbai)

 What is being termed as a guarantee is the obligation of the assessee company, in terms of “agreement for the sale and purchase of entire equity share capital of Virgin Radion Holdings Ltd UK” dated 30^thMay 2008, which has led to the actual crystallization of sale on 30^th June 2008. The related agreement clause was, at the cost of repetition, ““In consideration of the seller entering into this agreement, …(the TIML-India), as primary obl

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