Held that the transaction of furnishing corporate  guarantee to overseas associated enterprises constituted an international transaction and would be subject to transfer pricing regulations. During the course of assessment proceedings, the assessee had itself agreed to charge guarantee fee at 0.8 per cent. Order of Commissioner (Appeals) to hold that the assessee had justified the charging of corporate guarantee fee at 0.8 per cent.is affirmed. (AY.2009-10, 2010-11, 2011-12)