https://www.taxtmi.com/caselaws?id=469238 Where a foreign currency loan is repayable in that currency, arm's length interest must be benchmarked to the currency-linked market rate, so LIBOR and the applicable spread applied instead of SBI PLR. No separate transfer pricing adjustment was warranted on outstanding receivables because working capital impact had already been factored into pricing. For section 14A read with Rule 8D, only investments that actually yielded exempt income were to be included in the computation. The warranty provision required verification as to whether it had crystallised into an ascertained liability; if so, it would be allowable and not added to book profits under section 115JB. The Revenue appeal was rejected as time-barred for inordinate delay without sufficient cause. en-us Thu, 20 Nov 2025 00:00:00 +0530 Wed, 10 Jun 2026 20:06:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469238 Where a foreign currency loan is repayable in that currency, arm's length interest must be benchmarked to the currency-linked market rate, so LIBOR and the applicable spread applied instead of SBI PLR. No separate transfer pricing adjustment was warranted on outstanding receivables because working capital impact had already been factored into pricing. For section 14A read with Rule 8D, only investments that actually yielded exempt income were to be included in the computation. The warranty provision required verification as to whether it had crystallised into an ascertained liability; if so, it would be allowable and not added to book profits under section 115JB. The Revenue appeal was rejected as time-barred for inordinate delay without sufficient cause. Case-Laws Income Tax Thu, 20 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469238