https://www.taxtmi.com/caselaws?id=797680 Foreign-currency loans repayable in US dollars are benchmarked by reference to LIBOR, with LIBOR plus 300 basis points treated as appropriate. Under the transactional net margin method, comparable companies require meaningful functional and product comparability; entities engaged in distinct engineering procurement and construction activities or manufacturing materially different products should be excluded. No separate arm's-length interest adjustment arises on delayed associated-enterprise receivables where no interest is charged to related or unrelated parties and margins are embedded in pricing. Section 14A read with Rule 8D does not permit a disallowance where no exempt income is received or accrues during the relevant year. en-us Wed, 19 Aug 2026 00:00:00 +0530 Wed, 26 Aug 2026 08:27:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797680 Foreign-currency loans repayable in US dollars are benchmarked by reference to LIBOR, with LIBOR plus 300 basis points treated as appropriate. Under the transactional net margin method, comparable companies require meaningful functional and product comparability; entities engaged in distinct engineering procurement and construction activities or manufacturing materially different products should be excluded. No separate arm's-length interest adjustment arises on delayed associated-enterprise receivables where no interest is charged to related or unrelated parties and margins are embedded in pricing. Section 14A read with Rule 8D does not permit a disallowance where no exempt income is received or accrues during the relevant year. Case-Laws Income Tax Wed, 19 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797680