Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fide disputes.

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....Corporate guarantees furnished by holding companies for subsidiaries constitute taxable supplies of services between related persons, including where provided without consideration. A guarantee is not an actionable claim, and a share-pledge arrangement may also amount to a guarantee where its operative terms secure the subsidiary's obligations. Gratuitous guarantees are not continuous supplies, but annual accounting disclosure may determine yearly valuation based on outstanding guaranteed debt. Rule 28(2) remains valid, but the requirement to adopt the higher of deemed value and actual consideration is read down where an actual commission is ascertainable. The valuation rule cannot apply to guarantees executed before its introduction, altho.........