Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment.

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....Internal comparable uncontrolled transactions should be preferred over external comparables for benchmarking fixed-rate Masala Bond interest where they arise in the same period and offer greater comparability. A floating external benchmark is inconsistent with the strict comparability required under the CUP method, resulting in deletion of the related transfer-pricing adjustment. Specialised operational and maintenance services received from an associated enterprise are not shareholder activities; where receipt and need are evidenced, their arm's length price cannot be fixed at nil without comparable uncontrolled transactions. The related adjustment was deleted. TDS credit requires factual verification, while interest for advance-tax deferment is chargeable only on returned income, not assessed income.....