Held  that section 92B of the Act provides for the meaning of international transactions and under the Explanation, the expression international transaction includes capital financing, include any type of long-term or short-term borrowings, purchase or sale of marketable securities or any type of advance, payments or deferred payment or receivable or any other debt arising during the course of business. Since the inclusive definition of international transaction includes the activities relating to capital financing and borrowings, new corporate guarantee transaction also falls under the category of international transactions.  That the calculation of the corporate guarantee fee at 0.5 per cent. is  justified. The excess amount added in the hands of the assessee was to be deleted. As regards   the claim of the assessee that the Assessing Officer  had not granted tax credit  the issue is restored to the Assessing Officer  for necessary verification.(AY.2018-19)