Master File Documentation related

To answer your query: -

 Consider lenders as on 31st December of the financial year (FY) for reporting purposes. -

 Include facilities sanctioned by lenders during the FY, even if they are not yet drawn or utilized. - Report the top ten unrelated lenders based on the amount of financing (-sanctioned or drawn) as on 31st December of the FY. In other words, you should consider the lenders as on 31st December of the FY and include all facilities sanctioned during the FY, even if they are not yet drawn or utilized.

 This will give a comprehensive picture of the financing arrangements of the international group as on the reporting date.

However, please consult the latest CBDT (Central Board of Direct Taxes) guidelines or the Income-tax website for any updates or clarifications on this matter.