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    <description>Employees&#039; contribution to ESIC remains deductible only when deposited within the statutory due date, so delayed remittance was disallowed. Interest-free loans and advances to associated enterprises were examined in their commercial context, including the group business structure and equity conversion, and no notional interest transfer pricing adjustment was sustained on the facts. Corporate guarantee to an associated enterprise was treated as an international transaction where actual bank cost was incurred, but benchmarking on banking margins was rejected; the adjustment was restricted to the actual guarantee cost with a limited markup, subject to verification that no double recovery had already been made.</description>
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