During relevant year assessee had undertaken international transaction with its AEs. Assessing Officer  made addition mark up of 2.58 per cent on corporate guarantee given by assessee. CIT(A) restricted arm’s length price of compensation for providing corporate guarantee at rate of 1 per cent as against 2.58 per cent computed by Assessing Officer. Tribunal held that Explanation to section 92B introduced by Finance Act, 2012 is prospective in nature and hence, not applicable to  relevant year  and since  there was no material on file to prove that assessee company had incurred any cost in providing corporate guarantee and transaction qua corporate guarantee entered into by assessee company with its AE was an international transaction, ALP of compensation for providing corporate guarantee could not have been determined. (AY. 2011-12)