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Transfer pricing adjustment - advance to subsidiary - even though this interest rate could reach upto 400 basis points in some cases there cannot be any good reason for holding that loan advanced to a subsidiary at 247 basis points above the LIBOR rate is not at an arm s length price. - Tri

Income Tax - Transfer pricing adjustment - advance to subsidiary - even though this interest rate could reach upto 400 basis points in some cases, there cannot be any good reason for holding that loan .....

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