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2021 (1) TMI 1294 - AT - Income TaxTP Adjustment - determining the arm’s length price of the appellant’s international transaction with its associated enterprises in respect of interest on loan advanced to wholly owned subsidiary thereby proposing an enhancement of returned income - computing interest at US LIBOR - HELD THAT:- We direct that transfer pricing adjustment qua the transaction of advancing loan by the taxpayer to its AE is to be determined at US LIBOR plus 170 basis points. Appeal of the assessee is allowed.
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