THE PR. COMMISSIONER OF INCOME-TAX vs. M/S CCL PRODUCTS (INDIA) PVT. LTD.,
Appeal is dismissed
ITTA/17/2020HC Andhra Pradesh20 Aug 2025
Bench: The Income Tax Appellate Tribunal Bench, Visakhapatnam Preferred Against The Income Tax Appeal Cit (A)-1, Guntur In Visakhapatnam Order Of The Commissioner Of Dated 06.04.2018 Bearing Appeal No. Ita No.10198/Cit{A)-1/Gnt/2014-15 & Preferred Against The Order Of The Assistant Commissioner Of Income Tax, Circle-1 (1), Guntur In Aaacc9552G/A.Y.2014-2015/Ito/Guntur, Pan/Gir.No: Dated 28.12.2017. Between: The Pr. Commissioner Of Income-Tax, Guntur. ...Appellant & M/S Ccl Products (India) Pvt. Ltd, Duggirala, Guntur District - 522 330 ...Respondent
For Respondent: SRI KARAN TALWAR
Section 151Section 260ASection 928
additional
substantial
questions of law for adjudication of the issues raised in the above appeal.
1
"Whether on the facts and in the circumstances of the case, the Corporate
guarantee
given
by
the
assessee
to
its
Associated
Enterprises
without
charging
any fee
or commission would
be
termed
as
an
"international
transaction" within the meaning of Sec.928 of the Income