During relevant year, assessee granted loan to AE without charging any interest. In transfer pricing proceedings, TPO applied rate of SBI PLR+300 bps and determined transfer pricing adjustment in respect of notional interest.-DRP confirmed said addition Tribunal held that loan to AE is an international transaction and it needs to be benchmarked for ALP determination, however in view of fact that loan was advanced to AE in Italy, ALP computed by TPO on basis of lending rate of banks in India was not sustainable  it was appropriate to charge interest on loan at LIBOR + 200 bps. (AY. 2009-10 to 2014-15)