Error in Designating AE as "Tested Party" and Misusing USD Bond Rates for ALP Benchmarking: Focus on Borrower's Creditworthiness.

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....TPO and DRP have committed a fallacy, firstly, by considering the AE as a “tested party” and secondly, relying upon USD Corporate Bond Rates to benchmark the ALP of the interest rate because the interest rates for bonds or loan has to be seen from the point of view of borrowers creditworthiness and not the lender’s creditworthiness. - AT....