Held that  parent company’s commitment to providing its subsidiary with the resources it needs to meet its financial obligations or to get credit. However, as the format of the letter of comfort asked for by the bank was not available, its impact on the interest to be charged on the loan could not be estimated. Though the adjustment made to the interest rate by the Assessing Officer in treating the letter of comfort as a bank guarantee could not be upheld, the assessee’s alternative argument of treating the interest rates prescribed under the head “Safe Harbour Rules”, that is, under rule 10TD(2A)(5), which was 6 months LIBOR plus 400 bps, was acceptable. The Assessing Officer was directed to treat this rate as the arm’s length price of the international transaction and make adjustment accordingly. Even according to the quote of the bank an identical upfront fee of 1.25 per cent. of the bank loan was charged. Therefore, the letter of comfort called for a separate adjustment to the interest.  Arm’s length price adjustment to be made accordingly. (AY. 2018-19)