https://www.taxtmi.com/caselaws?id=450252 Interest on outstanding receivables from an associated enterprise was held not to be absorbed by the assessee's Safe Harbour election because such interest is not part of an "eligible international transaction" under Rule 10TC. The transfer pricing adjustment was therefore sustained in principle. However, the benchmark rate adopted for the adjustment was considered excessive, and Tribunal precedent supported a lower rate of LIBOR plus 200 basis points. The rate was accordingly reduced from LIBOR plus 400 basis points, granting partial relief to the assessee. en-us Wed, 28 Feb 2024 00:00:00 +0530 Fri, 01 Mar 2024 07:32:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450252 Interest on outstanding receivables from an associated enterprise was held not to be absorbed by the assessee's Safe Harbour election because such interest is not part of an "eligible international transaction" under Rule 10TC. The transfer pricing adjustment was therefore sustained in principle. However, the benchmark rate adopted for the adjustment was considered excessive, and Tribunal precedent supported a lower rate of LIBOR plus 200 basis points. The rate was accordingly reduced from LIBOR plus 400 basis points, granting partial relief to the assessee. Case-Laws Income Tax Wed, 28 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450252