During relevant year assessee extended corporate guarantee to its AE  Assessee, however, did not charge any guarantee commission from AE in respect of said transaction  The  TPO benchmarked transaction of guarantee commission at rate of 1.25 per cent and, thus, certain addition was made to assessee’s ALP. Tribunal held restricted addition of guarantee commission to 0.50 per cent. During relevant year, assessee advanced certain loan to its AE-Assessee’s case was that it did not charge any interest on said loan due to precarious condition of AE. TPO made certain addition to assessee’s ALP in respect of interest on loan  Tribunal held that  commercial expediency of loan is wholly irrelevant in ascertaining ALP of interest on said loan advanced to AE. Order of TPO is affirmed.  (AY. 2014-15)