https://www.taxtmi.com/highlights?id=85072 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. en-us Wed, 22 Jan 2025 08:21:45 +0530 Wed, 22 Jan 2025 08:21:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=85072 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. Highlights Income Tax Wed, 22 Jan 2025 08:21:45 +0530 https://www.taxtmi.com/highlights?id=85072