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    <title>2015 (10) TMI 2624 - ITAT MUMBAI</title>
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    <description>Interest-free loans advanced to associated enterprises were treated as international transactions for transfer pricing purposes, and their arm&#039;s length price was benchmarked by reference to the LIBOR of the country where the funds were used, with an additional 2% markup accepted on the facts. The Tribunal also held that a uniform 12 months&#039; average LIBOR was inappropriate where the loans were repaid within shorter periods and the loan tenures were not uniform; the relevant loan periods needed verification before the correct LIBOR period could be applied. The appeal thus succeeded partly on the benchmark rate, while the LIBOR period issue was remitted for fresh consideration.</description>
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