that ICICI Bank has given a guarantee to the group in consideration of guarantee
ITA No.2074 & 2179/Ahd/2013
Assessment year ... Appellant for not charging guarantee fees has force and action of
TPO in adopting guarantee fees @ 2% without taking into consideration any comparable
instances
that ICICI Bank has
given a guarantee to the group in consideration of guarantee commission @ 0.75%
which can be treated as a CUP. None ... Appellant for not charging guarantee fees has force and action of TPO in
adopting guarantee fees @ 2% without taking into consideration any comparable instances
India , the Constitution Bench
held that recording of reasons:
"(i) guarantee consideration by the authority; (ii)
introduce clarity in the decisions; and (iii) minimise
more in line with
that of the American Courts. An important consideration
which has weighed with the Court for holding that an
administrative authority exercising ... this view are that the
requirement of recording reasons would (i) guarantee
consideration by the authority; (ii) introduce clarity in
10
the decisions
purchase contract or
order, in addition to a predetermined guarantee consideration.
Again, an indication contra to the contention that the non-resident
was providing management
more in line with that of the American Courts. An
important consideration which has weighed with the Court for
holding that an administrative authority exercising ... this view are that the requirement of recording reasons
would (i) guarantee consideration by the authority; (ii) introduce
clarity in the decisions; and (iii) minimise
more in
line with that of the American Courts. An important
consideration which has weighed with the Court for
holding that an administrative authority exercising ... this view are that the requirement
of recording reasons would (i) guarantee
consideration by the authority; (ii) introduce clarity
in the decisions; and (iii) minimise
more in line with that of the American Courts. An
important consideration which has weighed with the Court for
holding that an administrative authority exercising ... this view are that the requirement of recording reasons
would (i) guarantee consideration by the authority; (ii) introduce
clarity in the decisions; and (iii) minimise
employees for
promotion is obviously a fundamental right and a guarantee of fair
consideration. Relevant portion of the judgment read as under ... fundamental right guaranteed under Article 16 of the
Constitution. The guarantee of a fair consideration in matters
of promotion under Article 16 virtually flows from
crores in favour of Religare,
to guarantee the balance purchase consideration. Religare received an initial
purchase consideration of ₹10 crores from Strategic on June ... Purchase
Consideration". It is thus apparent that SBLC was not issued as a
consideration of the Assignment Agreement but was a guarantee