https://www.taxtmi.com/caselaws?id=465807 Whether prolonged overdue trade receivables from an AE constitute a separate international transaction warranting notional interest adjustment was decided against the assessee: given persistent non-realisation over years, the assessee's non-debt-free status and conduct benefiting the AE, and applying the Explanation to s. 92B, the delay beyond reasonable credit period was treated as an advance requiring separate benchmarking; TP adjustment on notional interest was upheld. The interest rate was partly modified: the TPO was directed to compute interest at LIBOR plus markup as per Rule 10CB, instead of LIBOR + 400. The claimed set-off of alleged excess remuneration against the TP adjustment was rejected as pertaining to a different, unrelated segment. The appeal was dismissed. en-us Tue, 26 Nov 2024 00:00:00 +0530 Fri, 09 Jan 2026 11:00:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465807 Whether prolonged overdue trade receivables from an AE constitute a separate international transaction warranting notional interest adjustment was decided against the assessee: given persistent non-realisation over years, the assessee's non-debt-free status and conduct benefiting the AE, and applying the Explanation to s. 92B, the delay beyond reasonable credit period was treated as an advance requiring separate benchmarking; TP adjustment on notional interest was upheld. The interest rate was partly modified: the TPO was directed to compute interest at LIBOR plus markup as per Rule 10CB, instead of LIBOR + 400. The claimed set-off of alleged excess remuneration against the TP adjustment was rejected as pertaining to a different, unrelated segment. The appeal was dismissed. Case-Laws Income Tax Tue, 26 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465807