https://www.taxtmi.com/caselaws?id=799034 Corporate guarantee commission for borrowings of an overseas group entity is benchmarked at 0.5% using transaction-specific comparability. A parent-company guarantee for an overseas subsidiary, accepted at the same rate, provides a reliable internal indicator. Bank guarantees issued in ordinary banking business are not comparable to intra-group corporate guarantees. Nor does the yield differential on five-year unsecured bonds based on notional credit ratings reliably measure a guarantee effective for about 40 months. The transfer-pricing adjustment must therefore be recomputed by restricting the arm's length guarantee commission to 0.5%. en-us Thu, 20 Aug 2026 00:00:00 +0530 Wed, 16 Sep 2026 08:38:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799034 Corporate guarantee commission for borrowings of an overseas group entity is benchmarked at 0.5% using transaction-specific comparability. A parent-company guarantee for an overseas subsidiary, accepted at the same rate, provides a reliable internal indicator. Bank guarantees issued in ordinary banking business are not comparable to intra-group corporate guarantees. Nor does the yield differential on five-year unsecured bonds based on notional credit ratings reliably measure a guarantee effective for about 40 months. The transfer-pricing adjustment must therefore be recomputed by restricting the arm's length guarantee commission to 0.5%. Case-Laws Income Tax Thu, 20 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799034