Court Upholds 7.375% Interest Rate Plus 1% Markup as Arm's Length for USD Loan Transfer Pricing Adjustment.

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....TP adjustment - Since the funds have been borrowed in USD and also advanced in USD, the currency and exchange risks are minimised and the only risk to be considered is the lending risk for determining the markup. - No infirmity in the impugned order in treating 7.375% plus markup of 1% as the arm’s length rate of interest in respect of loan advanced by the assessee to its AE. - AT....