{"id":1530,"date":"2026-09-22T19:00:43","date_gmt":"2026-09-22T19:00:43","guid":{"rendered":"https:\/\/theleagle.in\/?p=1530"},"modified":"2026-09-22T19:00:44","modified_gmt":"2026-09-22T19:00:44","slug":"corporate-guarantees-and-arbitrary-provisions-in-gst","status":"publish","type":"post","link":"https:\/\/theleagle.in\/?p=1530","title":{"rendered":"Corporate Guarantees and Arbitrary Provisions in GST\u00a0\u00a0"},"content":{"rendered":"<div id=\"bsf_rt_marker\"><\/div>\n<p><strong>Introduction&nbsp;<\/strong><\/p>\n\n\n\n<p>The Revenue Department\u2019s attempt to levy Goods and Services Tax (\u2018GST\u2019) on corporate guarantees has attracted divergent judicial opinions. The Bombay High Court in&nbsp;<a href=\"https:\/\/indiankanoon.org\/doc\/128537955\/\">M\/s. D P Jain &amp; Co Infrastructure Pvt Ltd v Union of India<\/a>&nbsp;(&#8216;DP Jain case\u2019) held that a holding company issuing a corporate guarantee to its subsidiary company cannot be subjected to GST. The reason? There was no consideration involved. While the Gujarat High Court in&nbsp;<a href=\"https:\/\/indiankanoon.org\/doc\/109194998\/\">Torrent Power Ltd v Union of India<\/a>&nbsp;(\u2018Torrent Power case\u2019) held that absence of consideration was not fatal to levy of GST on corporate guarantees issued by a holding company. But the Gujarat High Court read down the valuation mechanism prescribed under Rule 28(2), Central Goods and Services Rules, 2017 (\u2018CGST Rules, 2017\u2019). Rule 28(2) provided that the value of services for issuing corporate guarantee:&nbsp;<\/p>\n\n\n\n<p><em>\u2026 shall be deemed to be one per cent of the amount of such guarantee offered per annum, or the actual consideration,&nbsp;<u>whichever is higher<\/u>.&nbsp;<\/em>(emphasis added)&nbsp;<\/p>\n\n\n\n<p>The Gujarat High Court read down \u2018whichever is higher\u2019 and held that it was arbitrary to apply the 1% rule even when in situations where the actual consideration paid for the corporate guarantee was available. Especially in cases where the consideration was less than 1% of the amount of guarantee.&nbsp;<\/p>\n\n\n\n<p>This article briefly maps the evolution of law relating to levy of GST on corporate guarantees and identifies absence of consideration and value of supply rules as the core issues. Relying on the above mapping, this article makes two arguments: (i) absence of consideration, per se, does not make a supply non-taxable under GST and the Bombay High Court\u2019s conclusion in DP Jain case was incorrect to that extent; (ii) applicability of GST on various supplies involves legislating a series of legal fictions that rely on approximation. For example, Section 17(4) of the Central Goods and Services Act, 2017 (\u2018CGST Act, 2017\u2019) provides banks and financial institutions the option to compute their input tax credit (\u2018ITC\u2019) by apportioning between taxable and exempt supplies or opt for fifty per cent of the eligible ITC and allow the rest to lapse. However, I suggest that Section 17(4) is not arbitrary because it provides taxpayers an option and does not impose the \u201850% ITC rule\u2019 irrespective of facts.&nbsp;&nbsp;<\/p>\n\n\n\n<p>Finally, this article states that courts have consistently endorsed that the Parliament and the Revenue Department enjoy a wide leeway in taxation laws. And the leeway extends to incorporation of deeming fictions and prescribing random numbers such as \u201850% ITC rule\u2019 or \u20181% of the corporate guarantee rule\u2019. However, the wide leeway does not extend to implement a deeming fiction that does not provide a choice to taxpayers. Applying the above dictum to Rule 28(2) of the CGST Rules, 2017, this article concludes that in Torrent Power case, the Gujarat High Court was correct in reading down the 1% of the corporate guarantee rule. This is because even if a lower consideration was involved, it mandatorily applied the deemed 1% valuation and created an unjustifiable and onerous obligation on taxpayers.&nbsp;&nbsp;&nbsp;&nbsp;<\/p>\n\n\n\n<p><strong>The Oversight in DP Jain Case<\/strong><\/p>\n\n\n\n<p>In DP Jain case, the Bombay High Court had to determine if the issuance of corporate guarantee by a holding company to its subsidiaries, without any consideration, was taxable under the CGST Act, 2017. The Bombay High Court answered in the negative and relied on the Supreme Court\u2019s decision in&nbsp;<a href=\"https:\/\/indiankanoon.org\/doc\/175254476\/\">Commissioner of CGST and Central Excise v M\/S Edelweiss Financial Services Ltd<\/a>&nbsp;(\u2018Edelweiss case\u2019) to support its conclusion. In Edelweiss case, the Supreme Court had held that issuance of corporate guarantees to group companies without consideration is not a taxable service. The case involved determination of levy of service tax and interpretation of relevant provisions the Finance Act, 1994. The Supreme Court correctly held that &#8211; reading Section 65(12) with Section 65B(44) and Section 66B of the Finance Act, 1994 demonstrated &#8211; the issuance of corporate guarantee to group companies without any consideration did not amount to banking and financial services since the definition of service contemplated a consideration.&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;<\/p>\n\n\n\n<p>In DP Jain\u2019s case, the Bombay High Court relied on Edelweiss case and arrived at the same conclusion. But the Bombay High Court failed to distinguish the cases on facts. Edelweiss case was decided under the Finance Act, 1994 while DP Jain case was involved levy of GST under the CGST Act, 2017. It was incumbent on the Bombay High Court examine Section 7 in tandem with Schedule II of the CGST Act, 2017. The former defines supply to include supply of goods or services \u2018made or agreed to be made for a consideration\u2019 by a person in the course or furtherance of business. However, Schedule II introduces a deeming fiction and enlists a list of transactions that are to be treated as supply even if they do not involve a consideration. Entry 2, Schedule II states:<\/p>\n\n\n\n<p><em>Supply of goods or services or both between related persons or between distinct persons as specified in&nbsp;section 25, when made in the course or furtherance of business<\/em>:<\/p>\n\n\n\n<p>Further, a reading of Section 15 with Section 25 of the CGST Act, 2017 reveals that a holding company and its group companies can be considered as related persons as mentioned in Entry 2, Schedule II. Thus, presuming all other ingredients are fulfilled, a holding company issuing a corporate guarantee to its subsidiary company even without a consideration, will be considered as supply.&nbsp;<\/p>\n\n\n\n<p>In DP Jain case, the Bombay High Court\u2019s reliance on the ratio of Edelweiss case was based on the erroneous assumption that provisions of the CGST Act, 2017 are pari materia with the Finance Act, 1994. And did not consider the deeming fiction of Schedule II. Thus, the Bombay High Court\u2019s conclusion that consideration is an essential element to levy GST on issuance of corporate guarantees is incorrect.&nbsp;&nbsp;&nbsp;<\/p>\n\n\n\n<p><strong>Value of Supply Under Scrutiny in Torrent Power Case&nbsp;<\/strong><\/p>\n\n\n\n<p>In Torrent Power case, the Gujarat High Court examined Section 7 along with Entry 2, Schedule II to correctly observe that if a holding company issued a corporate guarantee to its subsidiary without a consideration it constituted as supply under the CGST Act, 2017. The valuation mechanism prescribed in Rule 28(2), CGST Rules, 2017 proved to be most consequential and is the focus of this article.&nbsp;&nbsp;<\/p>\n\n\n\n<p>The Gujarat High Court read down the phrase \u2018whichever is higher\u2019 in Rule 28(2), CGST Rules, 2017 due to three main reasons: (i) because it arbitrarily fixed 1% as the benchmark for value of corporate guarantee even if the actual consideration was less; (ii) petitioners cannot be denied the option to choose the valuation as per actual consideration, as available to taxpayers under similar safe harbour rules such as Rule 10TD, Income Tax Rules, 1962; (iii) the Revenue Department\u2019s apprehension of litigation on value of corporate guarantee is not a sufficient reason to accept statutory provisions on \u2018indeterminate happenings\u2019. Citing the above three reasons, the Gujarat High Court concluded that:&nbsp;<\/p>\n\n\n\n<p>\u2026&nbsp;<em>we find that the expression used in Rule 28(2) of the CGST Rules to the extent &#8220;whichever is higher&#8221; after fixing 1% flat value along with &#8220;actual consideration&#8221; is arbitrary and is hit by Article 14 and 19(1)(g) of the Constitution of India, and is ultra vires.&nbsp;<\/em>(para 108)<\/p>\n\n\n\n<p>The Gujarat High Court also added that where the loan and corporate guarantee extend into multiple years, the tax liability is likely to impose a significant burden on taxpayers if the 1% valuation mechanism is applied.&nbsp;<\/p>\n\n\n\n<p>The Gujarat High Court\u2019s second reason brings into focus a core issue. The GST laws have several examples where a deeming fiction is introduced to simplify the applicability and implementation of its provisions. Let me use two examples to draw analogy with Rule 28(2) of the CGST Rules, 2017.&nbsp;<\/p>\n\n\n\n<p><strong>Drawing a Line for Arbitrariness&nbsp;<\/strong><\/p>\n\n\n\n<p>In&nbsp;<a href=\"https:\/\/indiankanoon.org\/doc\/48062053\/\">Munjaal Manishbhai Bhatt v Union of India<\/a>, the Gujarat High Court decided on validity of Entry 3(if) of Notification No. 11\/2017 \u2013 Central Tax (Rate). The petitioners had challenged the prescribed valuation mechanism. As per Entry 3(if), where construction services involved transfer in share of land, a deduction of one-third of total consideration charged shall be given for the land. The deemed fiction achieved two things: (i) ensured that value of land was kept outside GST\u2019s purview since sale of immovable property was not taxable under GST; (ii) prescribed a flat value of land as one-third of the total consideration paid for the construction services relating to land. The Gujarat High Court struck the valuation mechanism and held that it led to arbitrary consequences.&nbsp;<\/p>\n\n\n\n<p>The Gujarat High Court\u2019s primary reasoning was that application of a fixed percentage should only be resorted to when actual value of land is not ascertainable. The High Court held that:&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;<\/p>\n\n\n\n<p><em>\u2026 the mandatory deduction of 1\/3rd for value of land is not sustainable in cases where the value of land is clearly ascertainable or where the value of construction service can be derived with the aid of valuation rules, such deduction can be permitted at the option of a taxable person particularly in cases where the value of land or undivided share of land is not ascertainable<\/em>. (para 123)<\/p>\n\n\n\n<p>The Gujarat High Court added that: (i) deeming fictions such as fixed valuation mechanisms can only be justified when actual costs are not available; (ii) the Revenue Department had adequate mechanisms under Rules 27-31 of the CGST Rules, 2017 to determine value of supply; (iii) the Revenue Department cannot justify flat rates on the pretext of tax avoidance.&nbsp;<\/p>\n\n\n\n<p>One can compare Rule 28(2) of the CGST Rules and 2017&nbsp;Entry 3(if) of Notification No. 11\/2017 \u2013 Central Tax (Rate) with Section 17(4) of the CGST Act, 2017. While the first two related to valuation mechanisms, the latter prescribes a valuation mechanism. Section 17(4) of the CGST Act, 2017 provides banks and financial institutions an option to either claim their ITC by computing and apportioning their taxable and exempt supplies. Or avail fifty per cent of the eligible ITC and allow the rest to lapse. The crucial difference is that the latter does not mandate a \u201850% ITC rule\u2019. Instead, it gives the taxpayer an option to opt for it or compute their eligible ITC. The reason for offering this option to banks and financial institutions is that supply both taxable and exempt supplies. For example, extending loans and accepting deposits are exempt supplies but a fee charged for executing standing instructions is taxable. Depending on the quantity and volume of inputs on which banks pay GST such as office supplies, furniture, software, etc. the banks must undertake a detailed exercise to calculate their eligible ITC. Section 17(4) offers them an option of availing half of their eligible ITC instead of computing their ITC to the last decimal point. Even if 50% ITC is an approximation or a flat rate, by providing an option to taxpayers Section 17(4) cannot be termed as arbitrary or discriminatory.&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;<\/p>\n\n\n\n<p><strong>Conclusion&nbsp;<\/strong><\/p>\n\n\n\n<p>Courts have consistently endorsed the doctrine that in relating to taxation laws, the&nbsp;<a href=\"https:\/\/indiankanoon.org\/doc\/1033021\/\">legislature enjoys a wide latitude<\/a>&nbsp;to enact provisions. This wide latitude extends to the Revenue Department enacting secondary legislation such as Rule 28(2), CGST Rules, 2017. While the wide latitude allows inclusion of deeming provisions such as in Schedule II of the CGST Act, 2017 or random approximations such as in Section 17(4) of the CGST Act, 2017. However, courts have not shied away from terming some of these provisions as arbitrary or discriminatory if they prescribe flat valuation mechanisms and do not permit taxpayers to take actual consideration into account. By eliminating the discretion and choice of taxpayers, even in cases where the actual consideration was available or was lesser in amount, the provisions led to arbitrary consequences. On the touchstone of above dictum, the Gujarat High Court was correct in terming \u2018whichever is higher\u2019 phrase in Rule 28(2) of the CGST Rules, 2017 as arbitrary and reading it down.&nbsp;&nbsp;&nbsp;<\/p>\n","protected":false},"excerpt":{"rendered":"<p>Introduction&nbsp; The Revenue Department\u2019s attempt to levy Goods and Services Tax (\u2018GST\u2019) on corporate guarantees has attracted divergent judicial opinions. The Bombay High Court in&nbsp;M\/s. D P Jain &amp; Co Infrastructure Pvt Ltd v Union of India&nbsp;(&#8216;DP Jain case\u2019) held that a holding company issuing a corporate guarantee to its subsidiary company cannot be subjected [&hellip;]<\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_themeisle_gutenberg_block_has_review":false,"cybocfi_hide_featured_image":"","footnotes":""},"categories":[137],"tags":[356,12,40,31,94,404,405],"class_list":["post-1530","post","type-post","status-publish","format-standard","hentry","category-there-are-two-certainties-in-life-taxes-and-complaints-about-taxes","tag-corporate-guarantees","tag-gst","tag-gujarat-high-court","tag-itc","tag-ravpratapsingh","tag-torrent-power","tag-valuation"],"yoast_head":"<!-- This site is optimized with the Yoast SEO plugin v28.1 - https:\/\/yoast.com\/product\/yoast-seo-wordpress\/ -->\n<title>Corporate Guarantees and Arbitrary Provisions in GST\u00a0\u00a0 - TheLeagle | Eco Law Forum<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/theleagle.in\/?p=1530\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Corporate Guarantees and Arbitrary Provisions in GST\u00a0\u00a0 - TheLeagle | Eco Law Forum\" \/>\n<meta property=\"og:description\" content=\"Introduction&nbsp; The Revenue Department\u2019s attempt to levy Goods and Services Tax (\u2018GST\u2019) on corporate guarantees has attracted divergent judicial opinions. The Bombay High Court in&nbsp;M\/s. D P Jain &amp; Co Infrastructure Pvt Ltd v Union of India&nbsp;(&#8216;DP Jain case\u2019) held that a holding company issuing a corporate guarantee to its subsidiary company cannot be subjected [&hellip;]\" \/>\n<meta property=\"og:url\" content=\"https:\/\/theleagle.in\/?p=1530\" \/>\n<meta property=\"og:site_name\" content=\"TheLeagle | Eco Law Forum\" \/>\n<meta property=\"article:published_time\" content=\"2026-09-22T19:00:43+00:00\" \/>\n<meta property=\"article:modified_time\" content=\"2026-09-22T19:00:44+00:00\" \/>\n<meta name=\"author\" content=\"Rav Singh\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:label1\" content=\"Written by\" \/>\n\t<meta name=\"twitter:data1\" content=\"Rav Singh\" \/>\n\t<meta name=\"twitter:label2\" content=\"Est. reading time\" \/>\n\t<meta name=\"twitter:data2\" content=\"9 minutes\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\\\/\\\/schema.org\",\"@graph\":[{\"@type\":\"Article\",\"@id\":\"https:\\\/\\\/theleagle.in\\\/?p=1530#article\",\"isPartOf\":{\"@id\":\"https:\\\/\\\/theleagle.in\\\/?p=1530\"},\"author\":{\"name\":\"Rav Singh\",\"@id\":\"https:\\\/\\\/theleagle.in\\\/#\\\/schema\\\/person\\\/1ded6db9ab6793d2bfd57d3237c2e09e\"},\"headline\":\"Corporate Guarantees and Arbitrary Provisions in GST\u00a0\u00a0\",\"datePublished\":\"2026-09-22T19:00:43+00:00\",\"dateModified\":\"2026-09-22T19:00:44+00:00\",\"mainEntityOfPage\":{\"@id\":\"https:\\\/\\\/theleagle.in\\\/?p=1530\"},\"wordCount\":1985,\"keywords\":[\"Corporate Guarantees\",\"GST\",\"Gujarat High Court\",\"ITC\",\"RavPratapSingh\",\"Torrent Power\",\"Valuation\"],\"articleSection\":[\"Two Certainties\"],\"inLanguage\":\"en-US\"},{\"@type\":\"WebPage\",\"@id\":\"https:\\\/\\\/theleagle.in\\\/?p=1530\",\"url\":\"https:\\\/\\\/theleagle.in\\\/?p=1530\",\"name\":\"Corporate Guarantees and Arbitrary Provisions in GST\u00a0\u00a0 - TheLeagle | Eco Law Forum\",\"isPartOf\":{\"@id\":\"https:\\\/\\\/theleagle.in\\\/#website\"},\"datePublished\":\"2026-09-22T19:00:43+00:00\",\"dateModified\":\"2026-09-22T19:00:44+00:00\",\"author\":{\"@id\":\"https:\\\/\\\/theleagle.in\\\/#\\\/schema\\\/person\\\/1ded6db9ab6793d2bfd57d3237c2e09e\"},\"breadcrumb\":{\"@id\":\"https:\\\/\\\/theleagle.in\\\/?p=1530#breadcrumb\"},\"inLanguage\":\"en-US\",\"potentialAction\":[{\"@type\":\"ReadAction\",\"target\":[\"https:\\\/\\\/theleagle.in\\\/?p=1530\"]}]},{\"@type\":\"BreadcrumbList\",\"@id\":\"https:\\\/\\\/theleagle.in\\\/?p=1530#breadcrumb\",\"itemListElement\":[{\"@type\":\"ListItem\",\"position\":1,\"name\":\"Home\",\"item\":\"https:\\\/\\\/theleagle.in\\\/\"},{\"@type\":\"ListItem\",\"position\":2,\"name\":\"Corporate Guarantees and Arbitrary Provisions in GST\u00a0\u00a0\"}]},{\"@type\":\"WebSite\",\"@id\":\"https:\\\/\\\/theleagle.in\\\/#website\",\"url\":\"https:\\\/\\\/theleagle.in\\\/\",\"name\":\"TheLeagle | Eco Law Forum\",\"description\":\"Analyse. Discuss. Learn.\",\"potentialAction\":[{\"@type\":\"SearchAction\",\"target\":{\"@type\":\"EntryPoint\",\"urlTemplate\":\"https:\\\/\\\/theleagle.in\\\/?s={search_term_string}\"},\"query-input\":{\"@type\":\"PropertyValueSpecification\",\"valueRequired\":true,\"valueName\":\"search_term_string\"}}],\"inLanguage\":\"en-US\"},{\"@type\":\"Person\",\"@id\":\"https:\\\/\\\/theleagle.in\\\/#\\\/schema\\\/person\\\/1ded6db9ab6793d2bfd57d3237c2e09e\",\"name\":\"Rav Singh\",\"image\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\\\/\\\/secure.gravatar.com\\\/avatar\\\/88a0d335c97cf709c9618d1d1c19ff328612a3144c986c21e6756b1e84bc15e5?s=96&d=mm&r=g\",\"url\":\"https:\\\/\\\/secure.gravatar.com\\\/avatar\\\/88a0d335c97cf709c9618d1d1c19ff328612a3144c986c21e6756b1e84bc15e5?s=96&d=mm&r=g\",\"contentUrl\":\"https:\\\/\\\/secure.gravatar.com\\\/avatar\\\/88a0d335c97cf709c9618d1d1c19ff328612a3144c986c21e6756b1e84bc15e5?s=96&d=mm&r=g\",\"caption\":\"Rav Singh\"},\"sameAs\":[\"https:\\\/\\\/www.ravsingh.in\\\/\"],\"url\":\"https:\\\/\\\/theleagle.in\\\/?author=2\"}]}<\/script>\n<!-- \/ Yoast SEO plugin. -->","yoast_head_json":{"title":"Corporate Guarantees and Arbitrary Provisions in GST\u00a0\u00a0 - TheLeagle | Eco Law Forum","robots":{"index":"index","follow":"follow","max-snippet":"max-snippet:-1","max-image-preview":"max-image-preview:large","max-video-preview":"max-video-preview:-1"},"canonical":"https:\/\/theleagle.in\/?p=1530","og_locale":"en_US","og_type":"article","og_title":"Corporate Guarantees and Arbitrary Provisions in GST\u00a0\u00a0 - TheLeagle | Eco Law Forum","og_description":"Introduction&nbsp; The Revenue Department\u2019s attempt to levy Goods and Services Tax (\u2018GST\u2019) on corporate guarantees has attracted divergent judicial opinions. The Bombay High Court in&nbsp;M\/s. D P Jain &amp; Co Infrastructure Pvt Ltd v Union of India&nbsp;(&#8216;DP Jain case\u2019) held that a holding company issuing a corporate guarantee to its subsidiary company cannot be subjected [&hellip;]","og_url":"https:\/\/theleagle.in\/?p=1530","og_site_name":"TheLeagle | Eco Law Forum","article_published_time":"2026-09-22T19:00:43+00:00","article_modified_time":"2026-09-22T19:00:44+00:00","author":"Rav Singh","twitter_card":"summary_large_image","twitter_misc":{"Written by":"Rav Singh","Est. reading time":"9 minutes"},"schema":{"@context":"https:\/\/schema.org","@graph":[{"@type":"Article","@id":"https:\/\/theleagle.in\/?p=1530#article","isPartOf":{"@id":"https:\/\/theleagle.in\/?p=1530"},"author":{"name":"Rav Singh","@id":"https:\/\/theleagle.in\/#\/schema\/person\/1ded6db9ab6793d2bfd57d3237c2e09e"},"headline":"Corporate Guarantees and Arbitrary Provisions in GST\u00a0\u00a0","datePublished":"2026-09-22T19:00:43+00:00","dateModified":"2026-09-22T19:00:44+00:00","mainEntityOfPage":{"@id":"https:\/\/theleagle.in\/?p=1530"},"wordCount":1985,"keywords":["Corporate Guarantees","GST","Gujarat High Court","ITC","RavPratapSingh","Torrent Power","Valuation"],"articleSection":["Two Certainties"],"inLanguage":"en-US"},{"@type":"WebPage","@id":"https:\/\/theleagle.in\/?p=1530","url":"https:\/\/theleagle.in\/?p=1530","name":"Corporate Guarantees and Arbitrary Provisions in GST\u00a0\u00a0 - TheLeagle | Eco Law Forum","isPartOf":{"@id":"https:\/\/theleagle.in\/#website"},"datePublished":"2026-09-22T19:00:43+00:00","dateModified":"2026-09-22T19:00:44+00:00","author":{"@id":"https:\/\/theleagle.in\/#\/schema\/person\/1ded6db9ab6793d2bfd57d3237c2e09e"},"breadcrumb":{"@id":"https:\/\/theleagle.in\/?p=1530#breadcrumb"},"inLanguage":"en-US","potentialAction":[{"@type":"ReadAction","target":["https:\/\/theleagle.in\/?p=1530"]}]},{"@type":"BreadcrumbList","@id":"https:\/\/theleagle.in\/?p=1530#breadcrumb","itemListElement":[{"@type":"ListItem","position":1,"name":"Home","item":"https:\/\/theleagle.in\/"},{"@type":"ListItem","position":2,"name":"Corporate Guarantees and Arbitrary Provisions in GST\u00a0\u00a0"}]},{"@type":"WebSite","@id":"https:\/\/theleagle.in\/#website","url":"https:\/\/theleagle.in\/","name":"TheLeagle | Eco Law Forum","description":"Analyse. Discuss. Learn.","potentialAction":[{"@type":"SearchAction","target":{"@type":"EntryPoint","urlTemplate":"https:\/\/theleagle.in\/?s={search_term_string}"},"query-input":{"@type":"PropertyValueSpecification","valueRequired":true,"valueName":"search_term_string"}}],"inLanguage":"en-US"},{"@type":"Person","@id":"https:\/\/theleagle.in\/#\/schema\/person\/1ded6db9ab6793d2bfd57d3237c2e09e","name":"Rav Singh","image":{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/secure.gravatar.com\/avatar\/88a0d335c97cf709c9618d1d1c19ff328612a3144c986c21e6756b1e84bc15e5?s=96&d=mm&r=g","url":"https:\/\/secure.gravatar.com\/avatar\/88a0d335c97cf709c9618d1d1c19ff328612a3144c986c21e6756b1e84bc15e5?s=96&d=mm&r=g","contentUrl":"https:\/\/secure.gravatar.com\/avatar\/88a0d335c97cf709c9618d1d1c19ff328612a3144c986c21e6756b1e84bc15e5?s=96&d=mm&r=g","caption":"Rav Singh"},"sameAs":["https:\/\/www.ravsingh.in\/"],"url":"https:\/\/theleagle.in\/?author=2"}]}},"_links":{"self":[{"href":"https:\/\/theleagle.in\/index.php?rest_route=\/wp\/v2\/posts\/1530","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/theleagle.in\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/theleagle.in\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/theleagle.in\/index.php?rest_route=\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/theleagle.in\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=1530"}],"version-history":[{"count":1,"href":"https:\/\/theleagle.in\/index.php?rest_route=\/wp\/v2\/posts\/1530\/revisions"}],"predecessor-version":[{"id":1531,"href":"https:\/\/theleagle.in\/index.php?rest_route=\/wp\/v2\/posts\/1530\/revisions\/1531"}],"wp:attachment":[{"href":"https:\/\/theleagle.in\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=1530"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/theleagle.in\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=1530"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/theleagle.in\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=1530"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}