Guarantee Fee Taxable Only at 10%; ITAT Rejects CIT(A)’s Move to Levy 40% Under ‘Other Income’

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Guarantee Fee Taxable Only at 10%; ITAT Rejects CIT(A)’s Move to Levy 40% Under ‘Other Income’

Direct Tax

Published on

12/12/2025

By Mariya Paliwala

Guarantee Fee Taxable Only at 10%; ITAT Rejects CIT(A)’s Move to Levy 40% Under ‘Other Income’

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The Income Tax Appellate Tribunal (ITAT) Delhi Bench has held that the guarantee fee received by a Japanese multinational trading company from its Indian subsidiaries can be taxed only at 10%, setting aside the Commissioner of Income Tax (Appeals)’ decision to classify the income as “other income” under Article 22 of the India–Japan DTAA and…

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Mariya Paliwala https://www.jurishour.in/

Mariya is the Senior Editor at Juris Hour. She has 7+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started her career as a freelance tax reporter in the leading online legal news companies.

Guarantee Fee Taxable Only at 10%; ITAT Rejects CIT(A)’s Move to Levy 40% Under ‘Other Income’

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