provisions of section 37(1) of the Act of
devolvement of SBLC of Rs. 30.98 crores considering capital loss and not
revenue loss in nature ... others
the assessee as to why Rs. 30.96 crores expenses incurred towards SBLC
devolvement should not be disallowed as per the provisions of the section
Standby Letter of Credit charges (SBLC) to M/s. Shalini Properties & Developers Limited
was allowable due to commercial expediency; whereas, the CIT(Appeals ... that the payment of
Rs.11,75,82,702/- as stand by SBLC to M/s. Shalini Properties & Developers Limited
was allowable
commission imputed on guarantee for issuance of Stand by Letter of Credit
(SBLC) for Associated Enterprise (AE).
4. We have heard the rival submissions ... account of freight, professional fees, salary, SBLC charges, telephone
charges for services, travelling expenses and other miscellaneous expenses
on behalf of Indo Jordan Clothing Company
commission imputed on guarantee for issuance of Stand by Letter of Credit
(SBLC) for Associated Enterprise (AE).
4. We have heard the rival submissions ... account of freight, professional fees, salary, SBLC charges, telephone
charges for services, travelling expenses and other miscellaneous expenses
on behalf of Indo Jordan Clothing Company
obtaining
such brand name by the appellant company and the payment of SBLC charges to
Shalini Properties & Developers P. Ltd is the entire issue ... Dunlop India Ltd and the appellant would
be obliged to bear the SBLC charges to be paid to M/s Shalini Properties & Developers
rate)
SBI Pune was required to
(Equivalent of 55 provide Bank Guarantee/SBLC
Million Euro) to SBI Bank Mumbai for the
said transaction.
Further ... Pune has not
charged any yearly/ongoing
commission on the outstanding
SBLC/Bank Guarantee
2 Bilcare AG INR 269.68 Cr. SBI Pune BILCARE
assessee
facilitated the Stand by Letter of Credit (in short 'SBLC') facility of
Rs.33,16,64,500/- to Lava HK by issuing ... period for which
credit limit was availed by Lava HK under SBLC. The same was
sustained by the ld. DRP for which the assessee
international
transaction i.e. Stand-by Letter of Credit (SBLC) issued to foreign AE.
4. In regard to this issue the relevant facts are that ... Appellant had issued a Standby Letter of Credit (hereinafter
referred as 'SBLC') of USD 5 million to its foreign Associate Enterprise
(hereinafter referred
carried out proper enquiry regarding the Standby Letter
of Credit (SBLC) arrangements. During TP proceedings, details of SBLCs
issued by banks in favour ... that in the transfer pricing
study itself, the assessee had treated the SBLC arrangement as an
international transaction. The assessee had stated that
Comparable 34,25,33,470
Uncontrolled Price
2. Standby letter of credit (SBLC for No Benchmarking 6,32,40,000
short) Required
3. Corporate Guarantee ... transactions in relation to Corporate
Guarantee (CG) and standby letter of credit (SBLC) were international transactions
and proceeded to make a reference
