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of The TPO benchmarked the ECB transaction using CUP method and SBI base rate as CUP, but failed to consider factors like credit rating, future revenue projections, and terms of loan agreement. The assessee didn't carry out proper TP analysis. The interest rate determination suffers from defects. SBI base rate alone isn't appropriate as banks don't lend at base rate to corporates. The DRP correctly held arm's length interest as SBI base rate plus 25 bps on simple interest basis, considering future growth projections and minimal risk. The ACIT had jurisdiction u/s 144B(8) to pass final assessment order after case transfer with CBDT approval. The final assessment order is valid.
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