Rate of Bank guarantee to be adjusted before using it as comparable against corporate guarantee

IT/ILT : In course of transfer pricing proceedings, TPO cannot determine arm's length price of corporate guarantee by mechanically picking up bank guarantee rates as external /internal CUPs, as the case may be; however, said rates may turn out to be appropriate CUPs if they are properly benchmarked after making due adjustments in accordance with provisions of Rule 10B of 1962 Rules