Where the adequacy of the ALP of the corporate guarantee fees determined by the assessee at 0.43 per cent of the amount of loan by taking the average of the guarantee fees that was paid by the assessee to various banks for standing guarantees on its behalf for certain third parties. It was held that a higher commission is to be paid for obtaining bank guarantee, as they are easily encashable in the event of default as in comparison to corporate guarantee provided by an assessee company to a bank for facilitating raising of loan by its AE. Therefore, the adequacy of the ALP of the corporate guarantee fees determined by the assessee cannot be called in question. (AY. 2012-13, 2013-14)