Corporate guarantee commission transfer pricing adjustment deleted beyond the rate accepted in earlier years.

Transfer pricing adjustment on corporate guarantee commission was tested against the assessee's earlier years, where the coordinate bench had already upheld restriction of the commission rate to 0.5% following the jurisdictional High Court decision. Because the facts for the year under appeal were identical, no different view was considered warranted. The adjustment was therefore deleted to the extent it exceeded the rate accepted in the earlier years, and the ground was allowed.

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Issues: Whether the transfer pricing adjustment in respect of corporate guarantee commission was sustainable.

Analysis: The issue was examined with reference to the assessee's earlier assessment years, where the coordinate bench had already upheld restriction of the corporate guarantee commission rate to 0.5% following the jurisdictional High Court decision. As the facts for the year under appeal were identical, no different view was found warranted.

Conclusion: The transfer pricing adjustment was deleted to the extent it exceeded the rate accepted in the assessee's earlier years, and the ground was allowed.

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