https://www.taxtmi.com/caselaws?id=794717 A corporate guarantee furnished to an associated enterprise is treated as an international transaction under section 92B because the statutory explanation includes guarantees within capital financing arrangements. The guarantee's role in enabling credit facilities and affecting the associated enterprise's financial position supports that characterisation. For benchmarking the arm's length commission, where the guarantee secured a term loan repaid in instalments and the exposure fluctuated during the year, the average of the opening and closing outstanding exposure is a more reasonable measure than the year-end balance alone. The commission is accordingly quantified on average exposure at 0.50%. en-us Fri, 12 Jun 2026 00:00:00 +0530 Fri, 10 Jul 2026 07:39:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794717 A corporate guarantee furnished to an associated enterprise is treated as an international transaction under section 92B because the statutory explanation includes guarantees within capital financing arrangements. The guarantee's role in enabling credit facilities and affecting the associated enterprise's financial position supports that characterisation. For benchmarking the arm's length commission, where the guarantee secured a term loan repaid in instalments and the exposure fluctuated during the year, the average of the opening and closing outstanding exposure is a more reasonable measure than the year-end balance alone. The commission is accordingly quantified on average exposure at 0.50%. Case-Laws Income Tax Fri, 12 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794717