https://www.taxtmi.com/caselaws?id=799135 Corporate guarantees issued for associated enterprises are treated as international transactions requiring arm's length benchmarking under Section 92B of the Income-tax Act. Where the assessee's bank facility letter provides a reliable internal comparable uncontrolled price, that rate is preferred to unadjusted external bank guarantee rates because bank and corporate guarantees differ in creditworthiness, security and risk. The corporate guarantee commission is restricted to 0.60%, after credit for commission recovered from associated enterprises. Additional TDS/TCS credit requires verification of supporting factual material before relief may be granted. en-us Fri, 28 Aug 2026 00:00:00 +0530 Thu, 17 Sep 2026 07:52:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799135 Corporate guarantees issued for associated enterprises are treated as international transactions requiring arm's length benchmarking under Section 92B of the Income-tax Act. Where the assessee's bank facility letter provides a reliable internal comparable uncontrolled price, that rate is preferred to unadjusted external bank guarantee rates because bank and corporate guarantees differ in creditworthiness, security and risk. The corporate guarantee commission is restricted to 0.60%, after credit for commission recovered from associated enterprises. Additional TDS/TCS credit requires verification of supporting factual material before relief may be granted. Case-Laws Income Tax Fri, 28 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799135