Assessee sold natural ingredients to its US AE and benchmarked same using Transactional Net Margin Method (TNMM).Accordingly, no TP adjustment was proposed by assessee.  Rejecting TNMM and adopting CUP as Most Appropriate Method (MAM), TPO proposed an adjustment. Tribunal held that in earlier years, TNMM method as adopted by assessee had constantly been accepted to be Most Appropriate Method as against observation of TPO. Accordingly no TP adjustment would be warranted on these transactions.  Assessee provided corporate guarantee of USD 4 Million US dollars to a US bank for extending credit facilities to one of its 100 per cent subsidiary/AE.  In its TP study report, assessee benchmarked said transaction and arrived at spread of 1.25 per cent on such transaction. Applying same to loan amount outstanding at month end, assessee worked out TP adjustment of Rs.18.74 Lacs. However, TPO held that said rate would apply to gross amount of guarantee and not on actual loan availed by AE. TPO worked out additional adjustment of Rs.1.20 Lacs.  DRP confirmed order of TPO Tribunal confirmed the order of lower authorities. (AY. 2014-15)