Counter guarantee with negligible risks cannot be compared with guarantee with high risk 

MUFG Bank Ltd. Vs ACIT (ITAT Delhi) ITAT Delhi held that counter guarantee with negligible risks can not per se be compared with guarantee offered by independent parties/ banks shouldering very high risk parameters as also observed by the co-ordinate bench in other assessment years. Facts- The assessee is a foreign company incorporated under the laws of Japan and is a tax resident of Japan. The assessee operates its banking business in India under the license from RBI and is primarily engaged in wholesale banking operations in distinction to retail banking. AO while framing the assessment orde...