https://www.taxtmi.com/caselaws?id=796406 Delayed receivables from associated enterprises constitute a separately benchmarkable international transaction because credit beyond the normal period provides a distinct financing benefit, even where the underlying software-development services are at arm's length. A debt-free taxpayer with no interest-bearing borrowings may not warrant a notional interest adjustment; the asserted debt-free period requires factual verification. For foreign-currency receivables, the benchmark should use a currency-linked international rate rather than a domestic rupee lending rate. The adjustment is to be recomputed using LIBOR plus 200 basis points after a sixty-day credit period from the invoice date. en-us Wed, 29 Jul 2026 00:00:00 +0530 Wed, 05 Aug 2026 08:48:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796406 Delayed receivables from associated enterprises constitute a separately benchmarkable international transaction because credit beyond the normal period provides a distinct financing benefit, even where the underlying software-development services are at arm's length. A debt-free taxpayer with no interest-bearing borrowings may not warrant a notional interest adjustment; the asserted debt-free period requires factual verification. For foreign-currency receivables, the benchmark should use a currency-linked international rate rather than a domestic rupee lending rate. The adjustment is to be recomputed using LIBOR plus 200 basis points after a sixty-day credit period from the invoice date. Case-Laws Income Tax Wed, 29 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796406