Assessee's Advances Not Quasi Capital; LIBOR Rate Inapplicable for ALP Adjustments, Micro Inks Ltd. Case Irrelevant 'sLength.

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....TP Adjustment on notional interest on advances - The assessee being unable to demonstrate that the advances were not in the nature of loan/advance but were quasi capital in nature and for commercially expedient purposes of the assessee and hence the LIBOR rate could not be applied to them for the purposes of making ALP adjustment on the interest to be charged, the decision of the Ahmedabad Bench in the case of Micro Inks Ltd. is not applicable to the assessee - AT....