TMI Blog2019 (1) TMI 1841X X X X Extracts X X X X X X X X Extracts X X X X ..... hould be computed @0.5% in terms of ratio of decision of this Tribunal rendered in Everest Kanto Cylinders Ltd. [ 2012 (11) TMI 1099 - ITAT MUMBAI] . HELD THAT:- TPO, adopting a rate of 2% pa., arrived at ALP of the same, based on number of days for which the CG remained in force. The adjustment thus worked out to ₹ 66.37 Lacs which was incorporated in the assessment order dated 24/04/20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Assessee by: Hiro Rai, Ld. AR ORDER Manoj Kumar Aggarwal, 1. Aforesaid appeal by assessee for Assessment Year [AY] 2011-12 contest the order of the Ld. Commissioner of Income-Tax (Appeals)-58 [CIT(A)], Mumbai, Appeal No. CIT(A)-58/TR-51/2015-16 dated 09/02/2017. The only issue involved under the appeal is computation of Arm Length Price [ALP] of certain Corporate Guarantee given ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... impugned AY, three more such guarantees were provided by the assessee for the benefit of other AEs as well, the details of which have already been noted by Ld. TPO in its order. No fees were charged by the assessee against the same on the ground that there was no special benefit to the AEs. The Ld. TPO, adopting a rate of 2% per annum, arrived at ALP of the same, based on number of days for which ..... X X X X Extracts X X X X X X X X Extracts X X X X
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