https://www.taxtmi.com/caselaws?id=791336 Transfer pricing comparables may be excluded where the entities are functionally dissimilar, including a KPO profile, high turnover, or where earlier year decisions in the same assessee's case have already treated them as unsuitable. Interest on overdue receivables from associated enterprises may be benchmarked at LIBOR plus 200 basis points where that approach is supported by prior year reasoning, rather than using SBI short-term deposit rates. The appropriate credit period for outstanding receivables is fact-specific and cannot be fixed mechanically at 120 days; section 92CE and Rule 10CB do not prescribe a normal credit period for interest benchmarking and instead relate to secondary adjustment. en-us Mon, 13 Apr 2026 00:00:00 +0530 Sat, 09 May 2026 07:13:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791336 Transfer pricing comparables may be excluded where the entities are functionally dissimilar, including a KPO profile, high turnover, or where earlier year decisions in the same assessee's case have already treated them as unsuitable. Interest on overdue receivables from associated enterprises may be benchmarked at LIBOR plus 200 basis points where that approach is supported by prior year reasoning, rather than using SBI short-term deposit rates. The appropriate credit period for outstanding receivables is fact-specific and cannot be fixed mechanically at 120 days; section 92CE and Rule 10CB do not prescribe a normal credit period for interest benchmarking and instead relate to secondary adjustment. Case-Laws Income Tax Mon, 13 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791336