Foreign-currency loan benchmarking follows the loan currency, while export hedging losses qualify as non-speculative business losses.

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....Foreign-currency loan interest must be benchmarked against the relevant currency's LIBOR-based rate, not domestic lending rates; the interest adjustment was deleted. Corporate guarantees were treated as international transactions, but commission was restricted to 0.50% of outstanding guarantees. For section 10A, separately claimed units require factual examination as independent undertakings, while exclusions from export turnover must also be excluded from total turnover. Exempt-income disallowance excludes interest where interest-free funds exceed investments, with administrative expenditure limited to investments yielding exempt income. Hedging losses on export-related forward contracts were treated as non-speculative revenue losses. Seve.........