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TMI Blog2018 (5) TMI 1811X X X X Extracts X X X X X X X X Extracts X X X X ..... ee for Assessment Year [AY] 2009-10 contest the order of the Ld. Commissioner of Income-Tax (Appeals)-15 [CIT(A)], Mumbai, Appeal No.CIT(A)-15/Curr.105/14-15 dated 12/11/2014. The only issue involved in the appeal is Transfer Pricing [TP] adjustment on account of corporate guarantee given by the assessee to one of its Associated Enterprises [AE]. The assessment for impugned AY was framed by Ld. As ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... overall business consideration. However, not convinced, Ld. TPO arrived at impugned TP adjustment against the same which was calculated at 5% per annum. The same has been incorporated in the quantum assessment order dated 21/03/2013. Aggrieved, the assessee contested the same without any success before Ld. CIT(A) vide impugned order dated 12/11/2014, wherein the stand of the Lower authorities has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of credit facility and therefore, the same was required to be compensated by its AE. Our view is duly supported by the decision of this Tribunal rendered in Everest Kanto Cylinders Ltd. Vs. DCIT [34 Taxmann.com 19] as affirmed by Hon'ble Bombay High Court on 08/05/2015 [58 Taxmann.com 254] wherein the rate of commission has been adopted @0.5%. Respectfully, following the same, we estimate the impu ..... X X X X Extracts X X X X X X X X Extracts X X X X
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