https://www.taxtmi.com/caselaws?id=797116 Corporate guarantees issued without consideration by holding companies for subsidiaries are treated as related-party supplies of services under Schedule I, supported by the subsidiary's economic benefit and the guarantee's business nexus. Rule 28(2) and Section 15(4) permit specialised valuation, but valuation should use ascertainable actual commission or charge rather than compulsorily imposing a higher deemed amount. Rule 28(2) applies prospectively from 26.10.2023 and cannot create a valuation-based tax burden for earlier guarantees, although continuing guarantees may be taxable thereafter. Circulars cannot create levies or operate inconsistently with statutory interpretation. Section 74 requires fraud, wilful misstatement, or intentional suppression; bona fide disputes over corporate-guarantee taxability and valuation do not meet that threshold. en-us Fri, 14 Aug 2026 00:00:00 +0530 Mon, 17 Aug 2026 08:38:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797116 Corporate guarantees issued without consideration by holding companies for subsidiaries are treated as related-party supplies of services under Schedule I, supported by the subsidiary's economic benefit and the guarantee's business nexus. Rule 28(2) and Section 15(4) permit specialised valuation, but valuation should use ascertainable actual commission or charge rather than compulsorily imposing a higher deemed amount. Rule 28(2) applies prospectively from 26.10.2023 and cannot create a valuation-based tax burden for earlier guarantees, although continuing guarantees may be taxable thereafter. Circulars cannot create levies or operate inconsistently with statutory interpretation. Section 74 requires fraud, wilful misstatement, or intentional suppression; bona fide disputes over corporate-guarantee taxability and valuation do not meet that threshold. Case-Laws GST Fri, 14 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797116