Corporate guarantee forms an international transaction for Transfer pricing

GOCL Corporation Ltd. Vs DCIT (ITAT Hyderabad)

Learned counsel’s first and foremost argument is that a corporate guarantee is a shareholder’s activity which has been wrongly treated as an international transaction u/s.92B read with Explanation inserted by the Finance Act, 2012 with retrospective effect from 01-04-2002. He next sought to draw a distinction between the twin impugned assessment years that such a corporate guarantee furnished in AY.2012-13 could not fall u/s.92B of the Act since the foregoing Explanation came to be inserted vide Finance

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