IT/ILT : Where TPO made addition to assessee's ALP taking a view that assessee had not charged any fee for corporate guarantee for taking loans in USA given on behalf of its AE, since TPO could not arrive at credit rating of AE without there being any analysis on creditworthiness of AE and, moreover, addition made by TPO on basis of difference between domestic bond yield and that of loan availed in USA could not be accepted as domestic yield so as to compare it with loans in US and rates charged
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