Corporate guarantees are outside the ambit of international transaction even after retro amendment t

IT/ILT : Capital financing transactions covered by clause (i) (c) of the Explanation to section 92B are international transactions only if they have any real bearing as distinct from contingent effect on the profits, income, losses or assets of the enterprise. Corporate guarantees issued for the benefit of AEs do not cost anything to the issuing enterprise and yet may provide certain comfort levels to the parties dealing with the AEs. These guarantees do not have any impact on profits, income, l