Held, that the aim was to examine whether there was any anomaly in the transaction which arose out of the special relationship between the assessee-creditor and the associated enterprise-debtor. Hence, the contention of not having actually earned any income could not come to the rescue of the assessee in such a scenario. What was relevant in determining the arm’s length price was the comparable uncontrolled transaction rather than commercial expediency. As a result, the adjustment in respect of corporate guarantees provided to the associated enterprises must be determined at the rate of 0.5 per cent. instead of 1.3 per cent. determined by the Revenue. (AY. 2014-15).