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of TP Adjustment - Issuance of the corporate guarantee in favor of subsidiary - To be treated as a shareholders' activity or not - non-charging of corporate guarantee commission - Not every transaction with a subsidiary can be called a shareholder's activity unless reasons are demonstrated with credible facts. - when Guarantee is covered in clause 92B (2)(1)(C) specifically and it is a capital financing transaction specifically included there in, it is unnecessary to stretch it to bring in to clause (d) of ' Provision of services'. - AT
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