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Outstanding receivables from AEs exceeding agreed credit period constitutes separate international transaction of providing capital financing/lending receivables, not subsumed under sales/services transaction. Such overdue receivables amount to providing funds to AE without charge, requiring separate benchmarking. TPO rightly benchmarked this transaction, but erred in applying SBI PLR of 13.27% instead of LIBOR rate for foreign currency receivables. ITAT directed TPO to apply LIBOR rate and determine appropriate mark-up over LIBOR based on risk factors involved in overdue receivables from AEs. Assessee's appeal allowed for statistical purposes.
Outstanding receivables from AEs exceeding agreed credit period constitutes separate international transaction of providing capital financing/lending receivables, not subsumed under sales/services transaction. Such overdue receivables amount to providing funds to AE without charge, requiring separate benchmarking. TPO rightly benchmarked this transaction, but erred in applying SBI PLR of 13.27% instead of LIBOR rate for foreign currency receivables. ITAT directed TPO to apply LIBOR rate and determine appropriate mark-up over LIBOR based on risk factors involved in overdue receivables from AEs. Assessee's appeal allowed for statistical purposes.
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