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    <title>2026 (7) TMI 120 - ITAT AHMEDABAD</title>
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    <description>Benchmarking interest on an ECB loan to an associated enterprise should be done under the Comparable Uncontrolled Price method, with a Libor plus spread where foreign currency lending conditions are the relevant comparables; the transfer pricing adjustment was therefore remitted for fresh computation by the TPO. The assessee&#039;s alternative method was treated as acceptable on the facts noted, and the rejection of that approach was considered erroneous. On the TDS credit issue, the assessment record showed a mismatch between the credit claimed and credit allowed, so the Assessing Officer was directed to verify the claim and grant credit in accordance with law.</description>
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