Transfer Pricing Adjustment Deemed Unnecessary Due to Negligible Profit in Corporate Guarantee Case.

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....TP Adjustment in respect of extension of performance/ corporate guarantee - Even if it is reckoned as international transaction, then also on FAR analysis and looking to fact that the reward or profit to the AE is almost negligible, i.e. the ultimate profit is not even 1%, the adjustment if at all would also be negligible on the facts of the present case. - No transfer pricing adjustment can be made on account of corporate guarantee - AT....