Corporate Guarantee vs Negative Lien: Key Transfer Pricing Clarification by ITAT Delhi

Vivek Jalan , Last updated: 01 December 2025  
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Consider a 100% subsidiary. Co. B provides a corporate guarantee to Bank C for Holding Co. A. This means that in case Co. A defaults, then Co. B would make good the borrowed amount to Bank C. A "negative lien," on the other hand, means an undertaking by the owner of assets to a lender not to sell th

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Vivek Jalan
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