VISEN INDUSTRIES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (TRANSFER PRICING )-4(3)(1), MUMBAI
Appeal of the assessee is allowed
ITA 3729/MUM/2024[2016-17]Status: DisposedITAT Mumbai22 May 2025AY 2016-17
Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am
For Appellant: Ms. Usha Gopalan, ARFor Respondent: Shri Mukesh Thakwani, Sr. DR
Section 250Section 271GSection 273BSection 40Section 92CSection 92DSection 92D(3)
transfer pricing order dated 28.10.2019 has considered comparable market rate for corporate guarantee commission @1.5% and accordingly has made adjustment to the ALP in respect of Corporate Guarantee by 0.5% as the assessee has already charged guarantee commission @ 1%, amounting to Rs. 1,34,40,410/-.
Therefore, contention of the assessee is rejected.
Visen Industries Ltd.
5.8 Thus, in view