The assessee Company in the business of port infrastructure facilities and engineering, construction and consultancy services, etc. The TPO ascertained the ALP of the corporate guarantee at 1.5% and accordingly made ALP adjustment of Rs. 2,81,99,740/.  The CIT (Appeals) restricted the adjustment made by the TPO to the rate of 0.5% following the decision of the Hon’ble Bombay High Court in the case of CIT Vs. Everest Kento Cylinders Ltd. (2015) 378 ITR 57 (Bom.) (HC). The ITAT held that on the peculiar facts of the case and in the light of yield spread method adopted by the assessee which has not been faulted by the Revenue, the ALP adjustment on account of corporate guarantee restricted to 0.35%. (AY. 2013-14)