Corporate guarantees are international transactions u/s 92B, per Finance Act 2012, impacting transfer pricing adjustments.

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....TP Adjustment - corporate guarantee forms an international transaction or not? - Explanation to Section 92B inserted vide the Finance Act, 2012 with retrospective effect from 01-04-2002 also includes a corporate guarantee. We thus hold that the tribunal’s all foregoing orders must make way for higher wisdom and decline the assessee’s first and foremost legal plea. - AT....