https://www.taxtmi.com/highlights?id=104213 Corporate guarantees issued for an associated enterprise's borrowing fall within capital financing and constitute international transactions where they enhance the enterprise's creditworthiness and expose the guarantor to risk. Arm's-length pricing is therefore required. Where no pricing method or transfer-pricing study computation is provided, an annual 0.5% guarantee fee determined using the uncontrolled-price standard under Rule 10AB is sustained. Guarantee fee is not profit derived from SEZ development and is ineligible for the SEZ deduction. Tax deducted at source credit reflected in Form 26AS requires verification before eligible credit is granted. en-us Sat, 26 Sep 2026 08:31:02 +0530 Sat, 26 Sep 2026 08:31:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=104213 Corporate guarantees issued for an associated enterprise's borrowing fall within capital financing and constitute international transactions where they enhance the enterprise's creditworthiness and expose the guarantor to risk. Arm's-length pricing is therefore required. Where no pricing method or transfer-pricing study computation is provided, an annual 0.5% guarantee fee determined using the uncontrolled-price standard under Rule 10AB is sustained. Guarantee fee is not profit derived from SEZ development and is ineligible for the SEZ deduction. Tax deducted at source credit reflected in Form 26AS requires verification before eligible credit is granted. Highlights Income Tax Sat, 26 Sep 2026 08:31:02 +0530 https://www.taxtmi.com/highlights?id=104213