TMI Blog2019 (9) TMI 473X X X X Extracts X X X X X X X X Extracts X X X X ..... nterprises, is not appropriate. This as on identical facts, this Court in the case of CIT v/s. Everest Kento Cylinders Ltd. [ 2015 (5) TMI 395 - BOMBAY HIGH COURT] held that corporate guarantee, cannot be compared with the guarantee provided by the commercial banks. In the above view, this Court held that the adoption of 0.50% as ALP for the fee for grant of corporate guarantee, would be the appr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er dated 31st May, 2016 passed by the Income Tax Appellate Tribunal (the Tribunal). The common impugned order dated 31st May, 2016 is in respect of Assessment Year 2009-10 and 2010-11 respectively. Thus, the two appeals. 2. Revenue urges only the following questions of law, for our consideration: (a) Whether on the facts and in the circumstance of the case and in law, the Tribu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... In fact, the impugned order extracts substantially from the order dated 29th April, 2016. The Revenue has not been able to show any challenge to the above order dated 29th April, 2016 of the Tribunal before this Court; (ii) We find that the impugned order has allowed the Respondent-Assessee s appeal while holding that the rate of 3% taken as ALP for the fee to grant corporate guaran ..... X X X X Extracts X X X X X X X X Extracts X X X X
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