"4. We have heard carefully heard the rival
contentions and perused relevant material on
record. In our opinion corporate guarantee
provided by the assessee brought certain
8
ITA No s . 1 55 7/ Mu m/ 2 01 7
benefits to its AE by way of credit facility and
therefore, the same was required to be
compensated by its AE. Our view is duly
supported by the decision of this Tribunal
rendered in Everest Kanto Cylinders Ltd. Vs.
DCIT [34 Taxmann.com 19] as affirmed by
Hon'ble Bombay High Court on 08/05/2015 [58
Taxmann.com 254] wherein the rate of
commission has been adopted @0.5%.
Respectfully, following the same, we estimate
the impugned additions @0.5% per annum. The
Ld. AO is directed to quantity the addition and
re-compute the income of the assessee in terms
of our above order."