TPO, levied corporate guarantee fees at rate of 1.22 per cent, 1.69 per cent and 1.27 per cent of respective loan amounts and made TP adjustment-On appeal the Tribbunal held that  arm’s length guarantee commission charge should be restricted at 0.5 per cent of guaranteed amount. Assessee-company operated various units of which some units were eligible for deduction under section 80-IA(10) (eligible units) and some were non-eligible units.  During year under consideration, non-eligible units were engaged in manufacturing of veneer and same was supplied to various buyers including eligible units.  Eligible units utilized veneer procured from other units for purposes of manufacturing finished product, i.e. plywood-TPO made downward adjustment in respect of purchase of eligible units from non-eligible units of assessee alleging that eligible units of assessee had earned more than ordinary profit than it could have actually earned had transaction between eligible and non-eligible units were undertaken at an arm’s length. On appeal the Tribunal held that   since TPO had not given any analysis to demonstrate how purchase of any material by eligible units from non-eligible units could have yielded extra profits, no downward adjustment of profit of eligible units could be sustained.  (AY. 2014-15)