Tribunal held that since loan and advances were granted in foreign currency, Euro-LIBOR would be appropriate benchmark that conforms to arm’s length standard under CUP Method , accordingly the upward adjustment made by DRP was to be deleted .Tribunal also held that no ALP adjustment could be made as said payment was reimbursement of cost. Tribunal also held that where corporate guarantee was extended by assessee-company as a shareholder activity, i.e., solely because of ownership interest with primary object to help its subsidiary company, protect its interest and not to earn interest income on same no adjustments could be made .Followed ACIT v. Emani Ltd. [IT Appeal No. 1958/Kol/2017, dated 3-4-2019. (AY. 2013-14)