Transfer Pricing Officer determined the arm’s length price of the international transaction relating to the provision by the assessee of a corporate guarantee for the loan availed of by its associated enterprise, applying a commission rate of 4.86 per cent. The Commissioner (Appeals) deleted the adjustment holding that provision of corporate guarantee was not an international transaction and did not consider the issue on the merits. On appeal, the Tribunal held that provision of corporate guarantee towards loan availed of by the associated enterprises constituted an international transaction under section 92B of the Income-Tax Act, 1961 and since the Commissioner (Appeals) had not dealt with the merits of the assessee’s submissions, restored the issue to the Assessing Officer for de novo adjudication after due and reasonable opportunity of being heard to the assessee. The High Court dismissed the assessee’s appeal holding no question of law arose.  SLP of assessee is dismissed (AY.2009-10)