M/S. AGRAWAL COAL CORPORATION P. LTD.,INDORE vs. THE DCIT -CIRCLE 1(1), INDORE
ITA 602/IND/2015[2010-11]Status: DisposedITAT Indore08 Mar 2017AY 2010-11
Bench: Shri D.T. Garasia & Shri O.P. Meena
Section
92B of the Income-tax Act is amended retrospectively
w.e.f. 01.04.2002, hence ALP of corporate guarantee has
to be determined, as it falls within scope & ambit of
international transactions and they directed to adopt the
corporate guarantee rate of 0.53%, which is considered as
arm’s length rate in many decisions of tribunals.
Respectfully following the same, an amount
