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Theissue to be decided in this appeal is with regard to allowability of deduction towards provision for warranties in the sum of Rs. 50,11,63,331/-.

Shanti Prime Publication Pvt. Ltd.

Section 92C of the Income-tax Act, 1961—Transfer pricing— ALP of corporate guarantee fee in respect of old guarantees to be determined at 3% in line with the decision take by this Tribunal for A.Y.2009-10 as the matter is pending before the Hon'ble Jurisdictional High Court in assessee's own case - - MAHINDRA & MAHINDRA LTD. V/s DEPUTY CIT - [2020] 26 ITCD Online 143 (ITAT-MUMBAI)