Corporate Guarantees Not Classified as International Transactions u/s 92B of Income Tax Act.

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....TP Adjustment - corporate guarantee - international transaction of not? - the issue of corporate guarantee were in the nature of share holder activity and the same could not be included in the provision for services under the definition of international transaction u/s. 92B of the Act. - when an assessee extends assistance to AE which does not cost anything to the assessee and particularly for which the assessee could not have realized money by giving it to someone else during the course of normal business such an assistance or accommodation does not have any bearing on its profit, income, loses or asset and therefore it is outside the ambit of international transaction u/s. 92B of the Act. - AT....