https://www.taxtmi.com/caselaws?id=791087 Transfer pricing for interest on external commercial borrowings must be benchmarked on contemporaneous facts where lender identity, jurisdiction, tenor, or rate structure materially change. The Tribunal noted that a shift from a Mauritius lender to a United States lender, together with changes from floating to fixed interest and an extended maturity period, required fresh benchmarking and made the original comparability analysis unreliable. It also held that RBI's all-in-cost ceiling is only a regulatory cap and cannot by itself establish arm's length price, though it may support the analysis. For the second borrowing, fixed-rate and period mismatches required re-benchmarking, and consistency could not override materially changed facts. en-us Mon, 23 Feb 2026 00:00:00 +0530 Wed, 06 May 2026 08:32:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791087 Transfer pricing for interest on external commercial borrowings must be benchmarked on contemporaneous facts where lender identity, jurisdiction, tenor, or rate structure materially change. The Tribunal noted that a shift from a Mauritius lender to a United States lender, together with changes from floating to fixed interest and an extended maturity period, required fresh benchmarking and made the original comparability analysis unreliable. It also held that RBI's all-in-cost ceiling is only a regulatory cap and cannot by itself establish arm's length price, though it may support the analysis. For the second borrowing, fixed-rate and period mismatches required re-benchmarking, and consistency could not override materially changed facts. Case-Laws Income Tax Mon, 23 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791087