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In the result, the appeal filed by the Revenue stands dismissed
1. On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the disallowance made by the Assessing Officer amounting of Rs. 9103879/- on account of guarantee fees (adjustment made by the Transfer Pricing Officer) on relying the decision of the Bombay High Court in the 2 case of Everest Kanto Cylinders