https://www.taxtmi.com/caselaws?id=779859 ITAT, DELHI held that the negative lien on receivables and pledge/mortgage on oil and gas blocks do not constitute a corporate guarantee and therefore fall outside the definition of "international transaction" under section 92B, so no transfer-pricing benchmarking is required; related grounds on interest rate were left open as consequential. The AO is directed to determine interest under section 234A by verifying whether the return was filed within the statutory or extended due date. Liability under sections 234B and 234D is consequential, while section 234C interest is chargeable only on returned income. en-us Wed, 08 Oct 2025 00:00:00 +0530 Tue, 14 Oct 2025 09:39:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779859 ITAT, DELHI held that the negative lien on receivables and pledge/mortgage on oil and gas blocks do not constitute a corporate guarantee and therefore fall outside the definition of "international transaction" under section 92B, so no transfer-pricing benchmarking is required; related grounds on interest rate were left open as consequential. The AO is directed to determine interest under section 234A by verifying whether the return was filed within the statutory or extended due date. Liability under sections 234B and 234D is consequential, while section 234C interest is chargeable only on returned income. Case-Laws Income Tax Wed, 08 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779859