https://www.taxtmi.com/caselaws?id=470430 An invoked corporate guarantee that crystallised into the guarantor's liability before the relevant year is not a subsisting international transaction capable of transfer-pricing benchmarking for that year. Where the associated enterprise defaulted, lenders invoked the guarantees, and settlement obligations were recorded as liabilities before the relevant year, no corporate-guarantee commission adjustment arises. An unpaid provision for settlement under an invoked guarantee does not constitute a deemed loan to the associated enterprise. Under the Indian Contract Act, a surety obtains recovery rights against the principal debtor only on actual payment or performance; until then, no recoverable debt exists and notional interest cannot be imputed. en-us Thu, 20 Mar 2025 00:00:00 +0530 Mon, 27 Jul 2026 19:07:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470430 An invoked corporate guarantee that crystallised into the guarantor's liability before the relevant year is not a subsisting international transaction capable of transfer-pricing benchmarking for that year. Where the associated enterprise defaulted, lenders invoked the guarantees, and settlement obligations were recorded as liabilities before the relevant year, no corporate-guarantee commission adjustment arises. An unpaid provision for settlement under an invoked guarantee does not constitute a deemed loan to the associated enterprise. Under the Indian Contract Act, a surety obtains recovery rights against the principal debtor only on actual payment or performance; until then, no recoverable debt exists and notional interest cannot be imputed. Case-Laws Income Tax Thu, 20 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470430