There is no business incentive involved in the guarantee price that a trust charges small-scale industries for third-party guarantees.
The Income Tax Appellate Tribunal (ITAT) Mumbai bench held that the guarantee fee charged by the trust for providing third-party guarantees to small-scale industries did not amount to a profit motive. The assessee, Credit Guarantee Fund Trust for Micro and Small Enterprises, is an irrevocable trust settled by the President of India, acting through the…
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