Court Rejects Argument: Corporate Guarantee to Associated Enterprises is Not an International Transaction, Orders Resolution by Tax Authorities.

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....TP Adjustment - Arm's length price of the corporate guarantee fee - Lower authorities have also included a letter of comfort as part of corporate guarantee - We reject the submissions of the ld. AR of the assessee that the issue of corporate guarantee by the assessee to its AEs is not an international transaction and direct the AO/TPO to decide the issue - AT....