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    <title>2020 (3) TMI 1505 - ITAT AHMEDABAD</title>
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    <description>Foreign-currency loans advanced to associated enterprises must be benchmarked under the Comparable Uncontrolled Price method against an international foreign-currency lending rate, with LIBOR accepted rather than domestic prime lending rates. The transfer-pricing adjustment therefore requires recomputation by applying the applicable LIBOR rate to the interest-free loans. Deductions for a loan and consultancy advance written off require documentary evidence that the amounts arose and were written off in the course of business. As the business nexus was not sufficiently substantiated, the deductions remain disallowed.</description>
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