M/S. TEGA INDUSTRIES LIMITED,KOLKATA vs. D.C.I.T., CIRCLE - 11(1), KOLKATA
In the result, the appeal filed by the assessee is partly allowed
ITA 1875/KOL/2024[2020-2021]Status: DisposedITAT Kolkata11 Dec 2025AY 2020-2021
Bench: Shri George Mathan & Shri Rakesh Mishra
Section 143(3)Section 144Section 144C(5)Section 92BSection 92CSection 92C(3)
capital financing and borrowings, in our view now corporate guarantee transaction also falls under the category of international transactions. In the instant case, undisputedly, the assessee has given corporate guarantee for loan borrowed by its subsidiary/SPV after acquiring the business. Certainly, with the help of such corporate guarantee interest burden of the AE has been lowered. Though, it is contended
