https://www.taxtmi.com/caselaws?id=471373 Transfer-pricing analysis treats notional interest on delayed associated-enterprise receivables as unwarranted where comparable non-associated enterprise customers receive the same extended interest-free credit. United States dollar-denominated loans to associated enterprises require arm's length benchmarking against a United States dollar LIBOR-based rate rather than domestic or other-currency borrowing rates. For the Section 10A deduction, foreign-currency telecommunication and overseas technical-service expenditure not recovered from customers and not included in turnover should not be excluded from export turnover. These principles require revision of the transfer-pricing and export-turnover computations in line with the taxpayer's positions. en-us Wed, 18 Oct 2023 00:00:00 +0530 Tue, 01 Sep 2026 13:06:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471373 Transfer-pricing analysis treats notional interest on delayed associated-enterprise receivables as unwarranted where comparable non-associated enterprise customers receive the same extended interest-free credit. United States dollar-denominated loans to associated enterprises require arm's length benchmarking against a United States dollar LIBOR-based rate rather than domestic or other-currency borrowing rates. For the Section 10A deduction, foreign-currency telecommunication and overseas technical-service expenditure not recovered from customers and not included in turnover should not be excluded from export turnover. These principles require revision of the transfer-pricing and export-turnover computations in line with the taxpayer's positions. Case-Laws Income Tax Wed, 18 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471373