India - Transfer Pricing Provisions Not Applicable to the Provision of Corporate Guarantees If No Costs Are Incurred
- P.R.K. Jhabakh
- International Transfer Pricing Journal, 2014 (Volume 21), No 4
- 23 July 2014
This article discusses the recent decision of the Delhi Income Tax Appellate Tribunal in Bharti Airtel Ltd v. Additional Commissioner of Income Tax, in which the Court held that transfer pricing provisions are not applicable to corporate guarantees provided by a company to its associated enterprises, as such guarantees do not have any impact on the profit, income, loss or assets of the company.