https://www.taxtmi.com/caselaws?id=469768 Repeatedly amended outbound loan terms to the Mauritius associated enterprise were treated as a long-term, higher-risk arrangement, so floating LIBOR benchmarking was rejected and an arm's length rate of 6.5% applied with credit for interest already offered to tax; separate interest on overdue receivables was not sustained. For power conversion charges, the assessee's open-market benchmark was accepted under the section 80IA market value framework, and the SBU-II deduction was upheld. Section 14A disallowance was confined to exempt-income years and was not carried into section 115JB book-profit computation. Depreciation on capitalised expenditure linked to the alleged contractor was disallowed, while the limitation cross-objections were dismissed. en-us Fri, 19 Dec 2025 00:00:00 +0530 Wed, 01 Jul 2026 15:29:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469768 Repeatedly amended outbound loan terms to the Mauritius associated enterprise were treated as a long-term, higher-risk arrangement, so floating LIBOR benchmarking was rejected and an arm's length rate of 6.5% applied with credit for interest already offered to tax; separate interest on overdue receivables was not sustained. For power conversion charges, the assessee's open-market benchmark was accepted under the section 80IA market value framework, and the SBU-II deduction was upheld. Section 14A disallowance was confined to exempt-income years and was not carried into section 115JB book-profit computation. Depreciation on capitalised expenditure linked to the alleged contractor was disallowed, while the limitation cross-objections were dismissed. Case-Laws Income Tax Fri, 19 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469768