https://www.taxtmi.com/caselaws?id=799772 Corporate guarantees furnished to associated enterprises fall within capital financing under Explanation (c) to section 92B and require arm's-length pricing because they enhance the enterprise's creditworthiness while exposing the guarantor to risk. In the absence of an independently substantiated fee computation, a 0.5% annual guarantee-fee rate under Rule 10AB was treated as reasonable, sustaining the transfer-pricing adjustment. Guarantee-fee profit is not derived from the eligible activity of developing a Special Economic Zone and therefore does not qualify for deduction under section 80-IAB(10). en-us Wed, 16 Sep 2026 00:00:00 +0530 Sat, 26 Sep 2026 08:31:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799772 Corporate guarantees furnished to associated enterprises fall within capital financing under Explanation (c) to section 92B and require arm's-length pricing because they enhance the enterprise's creditworthiness while exposing the guarantor to risk. In the absence of an independently substantiated fee computation, a 0.5% annual guarantee-fee rate under Rule 10AB was treated as reasonable, sustaining the transfer-pricing adjustment. Guarantee-fee profit is not derived from the eligible activity of developing a Special Economic Zone and therefore does not qualify for deduction under section 80-IAB(10). Case-Laws Income Tax Wed, 16 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799772