Assessee gave corporate guarantees to Royal Bank of Scotland for foreign currency loan availed by its AEs.  Assessee adopted yield spread approach to benchmark guarantee commission.  TPO  held that quote from Royal Bank of Scotland could not be a sound basis for computing interest differential as it was dated 1-4-2013, after end of relevant previous year and could not be applied for relevant assessment year. TPO ascertained ALP of corporate guarantee at 1.5 per cent by adopting quotations for bank guarantees from Indian banks. Held that   if rate differential between current market interests for guarantor and guarantee recipient was 70 bps at end of relevant previous year, it was reasonable to proceed on basis that such a differential would also prevail during relevant previous year and thus, benchmarking corporate guarantee at.35 per cent using yield spread approach was  upheld. (AY. 2013-14)