No TP adjustment if there was no risk involved in issuing performance guarantee on behalf of AE

TRANSFER PRICING : Where assessee did not charge commission for providing performance guarantee on behalf of its AE, in view of fact that once said guarantee was invoked, assessee would execute contract by using its own infrastructure and in turn would be eligible for entire contractual revenue and profit arising therefrom, it could be concluded that there was no risk involved in giving said guarantee and, thus,

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