Applicability of section 185 companies act 2013

A, B and C are closely held family companies. B and C are private limited company while A is a public limited (closed held) company. A has approach ABC Bank for funding while B would provide corporate guarantee. Below is the structure of the companies, request you help in understanding whether section 185 of companies act 2013 would be applicable and if applicable what are the clauses of section 185 are attracted.

A Ltd (public Limited company)	B Pvt Ltd (Private Limited company)	C Pvt ltd (Private Limited company)
Mr. X - Director	Mr. P - Director	Mr. P - Director
Mr. Y - Director	Mr. Q - Director	Mr. Q - Director
Mr. Z - Director
Mr. S - Director

C Pvt limited - 40%	Mr. X - 10%	Mr. P - 10%
Mr. X - 10%	Mr. Y - 5%
Mr. P - 10%	other family members - 55%	Mr. X - 20%
Mr. Y - 10%	Mr. P - 10%	Mr. S -10%
Mr. Z - 10%	Mr. Q - 20%	Other family members - 60%
Mr. S - 10%
Other family members - 10%

Hello!

As per notification dated 5th June, 2015, Section 185 shall not apply to a private company:

a) In whose share capital no other body corporate has invested any money; - not attracted in aforesaid case

b) if the bonowings of such a company from banks or financial institlrtions or any body corporate is less than twice of its paid up share capital or fifty crore rupees whichever is lower; and

(c) such a company has no default in repayment of such borrowings subsisting at the time of making transactions under this section.

If any one of the above clauses are attracted, than sec.185 shall apply to Company B

Assuming any one of the above clauses are attracted section 185 will be is applicable. However clauses (a) to (e) of Explanation to section 185 are not attracted to Company B.

Hence, Company A can give corporate guarantee to Company B.

Experts may please share their opinion, if different from above......