Transfer Pricing Case: AO to Assess Costs of Corporate Guarantees and Apply 0.5% Service Fee Adjustment.

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....TP Adjustment - Addition of Corporate Guarantee - Matter restored before the AO with the direction that, he will first ascertain the amount of expenditure actually incurred by the assessee in furnishing the five corporate guarantees and thereafter add 0.5% as the service fee for furnishing the guarantee. - AT....