2018 (5) TMI 1811

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....nbsp; 1. The captioned appeal by assessee 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 asses....

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....lity was contingent in nature and given for 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, whe....