https://www.taxtmi.com/caselaws?id=797116 Corporate guarantees furnished by holding companies for subsidiaries constitute taxable supplies between related persons even without a separate fee, including arrangements whose substance creates an undertaking to meet a subsidiary's default. Gratuitous guarantees are not continuous supplies because they lack periodic payment obligations, although yearly accounting recognition may determine time of supply. Rule 28(2) remains valid but must permit valuation based on actual commission where available rather than mandating the higher prescribed benchmark. The valuation rule applies only from 26 October 2023 and does not cover foreign recipients. Circulars must conform to these limits, while differential treatment of governmental and directors' guarantees is valid. Fraud-based GST proceedings cannot rest solely on a bona fide interpretative dispute without deliberate tax evasion. en-us Fri, 14 Aug 2026 00:00:00 +0530 Wed, 16 Sep 2026 12:33:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797116 Corporate guarantees furnished by holding companies for subsidiaries constitute taxable supplies between related persons even without a separate fee, including arrangements whose substance creates an undertaking to meet a subsidiary's default. Gratuitous guarantees are not continuous supplies because they lack periodic payment obligations, although yearly accounting recognition may determine time of supply. Rule 28(2) remains valid but must permit valuation based on actual commission where available rather than mandating the higher prescribed benchmark. The valuation rule applies only from 26 October 2023 and does not cover foreign recipients. Circulars must conform to these limits, while differential treatment of governmental and directors' guarantees is valid. Fraud-based GST proceedings cannot rest solely on a bona fide interpretative dispute without deliberate tax evasion. Case-Laws GST Fri, 14 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797116