Bank Guarantee Leads to Transfer Price Adjustment; Commission Must Reflect Arm's Length Price for Assessee's Benefit to Associated Enterprises.

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Full Text of the Document

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....Transfer price adjustment - Bank guarantee commission - There was a clear benefit accrued to the Associated Enterprises by the guarantee provided by the assessee and when such benefit was passed on by the assessee to the said Associated Enterprises, guarantee commission should have been charged at arm's length price. - AT....