LIBOR is best benchmark under transfer pricing for interest-free loan granted to AE

IT/ILT : Where assessee advanced interest-free loan to its AE, LIBOR is best basis for benchmarking interest rate and since there was no independent CUP rate available to benchmark said international transaction, as per RBI guidelines, Assessing Officer should adopt 6 months LIBOR + 150 basis points for three years and LIBOR + 250 basis points for five years