https://www.taxtmi.com/caselaws?id=450876 The ITAT Delhi held that outstanding receivables from Associated Enterprises constitute separate international transactions under Section 92B(i)(c) of the Income Tax Act. The Tribunal directed that notional interest adjustments on receivables should be computed following DRP directions, with LIBOR as appropriate benchmark rate plus reasonable mark-up. Interest charging requires case-by-case examination analyzing payment patterns over time, comparing with non-AE transactions. The AO must set off receivables cleared within 30 days or received in advance when computing adjustments. The assessee's appeal was partly allowed. en-us Tue, 05 Mar 2024 00:00:00 +0530 Thu, 14 Mar 2024 12:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450876 The ITAT Delhi held that outstanding receivables from Associated Enterprises constitute separate international transactions under Section 92B(i)(c) of the Income Tax Act. The Tribunal directed that notional interest adjustments on receivables should be computed following DRP directions, with LIBOR as appropriate benchmark rate plus reasonable mark-up. Interest charging requires case-by-case examination analyzing payment patterns over time, comparing with non-AE transactions. The AO must set off receivables cleared within 30 days or received in advance when computing adjustments. The assessee's appeal was partly allowed. Case-Laws Income Tax Tue, 05 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450876