Held that the rate of interest on loans advanced by the assessee to associated enterprises must conform to the rate of interest prevailing in the associated enterprises’ country of residence, wherein the loan was availed of. Therefore, the domestic prime lending rate could not be applied in respect of loans advanced in foreign currency to the associated enterprises situated overseas. Followed  CIT v. Cotton Naturals (I) P. Ltd (2015) 55 taxmann.com 523 (Delhi)(HC).  (AY. 2010-11)