Transfer pricing adjustment of corporate guarantee fee not sustained based on earlier years decision

DCIT Vs Alembic Pharmaceuticals Ltd. (ITAT Ahmedabad) ITAT Ahmedabad held that upward transfer pricing adjustment on account of corporate guarantee fee given to Associate Enterprise is not sustainable based on settled orders of Co-ordinate bench of Tribunal in earlier years. Accordingly, appeal of department dismissed. Facts- The assessee is engaged in the business of development, manufacturing and marketing of pharmaceuticals products, i.e. Formulations and Active Pharmaceuticals Ingredients. During the course of assessment proceedings, a reference was made by AO to the Transfer Pricing Offi...