Transfer Pricing: allocation of guarantee commission to limited-function branch upheld; ad hoc upward adjustment deleted on benchmarking analysis.

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....Transfer pricing dispute over benchmarking of a guarantee commission: the article explains that the tax authority applied an ad hoc upward adjustment using a CUP-based market rate, but a tribunal relied on earlier coordinate-bench analysis that the combined guarantee fee approximated 0.69% and the assessee's allocated share (about 57%) reflected limited functions, absence of independent risk-bearing, and a back-to-back counter guarantee; applying that reasoning the tribunal found the TPO/DRP ad hoc rate untenable and deleted the upward transfer pricing adjustment to the guarantee commission for the year under review.....