The Assessing Officer made an addition of Rs. 73,69,830 qua transfer pricing adjustment on account of provision of corporate guarantee by the assessee to its overseas associated enterprises, treating the interest rate of 1.3 per cent. based on average fees charged by State Bank of India. The Commissioner (Appeals) affirmed the addition qua corporate guarantee while reducing the adjustment to 0.5 per cent. instead of 1.3 per cent. as determined by the Transfer Pricing Officer. On appeals by the assessee and the Department the Tribunal held  that  that the Commissioner thoroughly analysed the peculiar facts and circumstances and deleted the addition. The order did not call for any interference. (AY.2015-16)