ITAT Airtel ruling - TP - free guarantees: Can it be stretched?

Delhi ITAT, in a path-breaking ruling, in Bharti Airtel case [TS-76-ITAT-2014(DEL)-TP], has held that issuance of corporate guarantee is not an international transaction u/s 92B since it does not have any bearing on profits, income, losses or assets of enterprise. Significantly, this ruling has allowed the assessee's plea after considering the definition of the term 'international transaction', amended retrospectively by Finance Act, 2012.


Do you agree with ITAT's view that corporate guarantee does not have any bearing on profits, losses or assets of an enterprise? Can this Tribunal ratio be also applied to other international transactions? Does this ruling alter the landscape of the hotly debated share valuation adjustments, that is at the doorstep of the Bombay High Court?