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2018 (9) TMI 1832 - AT - Income TaxTP Adjustment - rate of guarantee commission to be charged to the AE for provision of corporate guarantee - direction of the learned Commissioner (Appeals) to apply the commission rate of 0.5% to the corporate guarantee provided to the Associated Enterprise (AE) - HELD THAT:- As could be seen, the Transfer Pricing Officer has charged guarantee commission @ 2.25%. Whereas, the learned Commissioner (Appeals) relying upon the decision of Everest Kento Cylinders Ltd. [2015 (5) TMI 395 - BOMBAY HIGH COURT] has held that guarantee commission should be charged @ 0.5%. Since, the aforesaid decision of the learned Commissioner (Appeals) is in consonance with the view expressed by the Hon'ble Jurisdictional High Court (supra) and by different Benches of the Tribunal including Mumbai Benches, we uphold the decision of the learned Commissioner (Appeals) on the issue by dismissing the grounds raised.
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