Delhi Tribunal Rules on Transfer Pricing and Intra Group Financing Transactions
The Delhi Income-tax Appellate Tribunal has ruled on transfer pricing (TP) issues in relation to the issuance of a guarantee, providing loans in foreign currencies, and contributions to share capital with a delayed allotment of shares. Details of each are as follows.
Issuance of a guarantee
The Indian taxpayer issued a guarantee to a third party on behalf of its foreign subsidiary. No fee was char…
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