IN THE INCOME TAX APPELLATE TRIBUNAL “Guwahati” BENCH, GUWAHATI (Through virtual hearing at Kolkata) BEFORE SHRI RAJESH KUMAR, AM AND SHRIMANOMOHAN DAS, JM ITA No.140/GTY/2024 (Assessment Year: 2013-14)

Greenply Industries Ltd ACIT, Circle-1 Madgul Lounge, 5^th Floor, 23 Aaykar Bhawan, Milan Nagar, Vs. chetiaCental Road, Kolkata-

Dibrugarh-786001, Assam

700027, West Bengal (Appellant) (

Respondent)

PAN No. AAACG7284R Assessee by : Shri Ashok Tulsyan, AR Revenue by : Shri Sanjay Jha, DR Date of hearing: 02.12.2025 Date of pronouncement: 15.12.2025

O R D E R

Per Rajesh Kumar, AM:

This is an appeal preferred by the Revenue against the order of the Commissioner of Income-tax (Appeals), Kolkata-22(hereinafter referred to as the “Ld. CIT(A)”] dated 31.01.2024 for the AY 2013-14.

2. The ground raised by the Revenue are as under:-

“1. That on the facts and the circumstances of the case and in law, the Ld. CIT(A) has erred by restricting the guarantee fee rate to 0.5% which is much lower than the CG rate of 1.50%, 1.69% & 1.27% respectively as determined by the TPO, for SCB Loans, UOВ Loans and SBLC.

2. That on the facts and the circumstances of the case and in law, the Ld. CIT(A) has erred in stating