https://www.taxtmi.com/caselaws?id=471409 Transfer-pricing treatment of related-party balances permits netting overdue receivables against overdue payables when both arise with the same associated enterprise and relevant details are available; where payables exceed receivables, no notional-interest adjustment survives. Foreign-currency external commercial borrowings require LIBOR-based interest benchmarking, with the spread determined by tenure and risk; LIBOR plus 200 basis points was retained on consistency. Royalty cannot be assigned an arm's length price of nil through a benefit test outside prescribed methods when technical support is established. Entity-level TNMM aggregation with connected transactions supported the royalty payment, as the taxpayer's margin exceeded comparables, rendering the nil-price adjustment unsustainable. en-us Wed, 08 Oct 2025 00:00:00 +0530 Tue, 01 Sep 2026 19:02:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471409 Transfer-pricing treatment of related-party balances permits netting overdue receivables against overdue payables when both arise with the same associated enterprise and relevant details are available; where payables exceed receivables, no notional-interest adjustment survives. Foreign-currency external commercial borrowings require LIBOR-based interest benchmarking, with the spread determined by tenure and risk; LIBOR plus 200 basis points was retained on consistency. Royalty cannot be assigned an arm's length price of nil through a benefit test outside prescribed methods when technical support is established. Entity-level TNMM aggregation with connected transactions supported the royalty payment, as the taxpayer's margin exceeded comparables, rendering the nil-price adjustment unsustainable. Case-Laws Income Tax Wed, 08 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471409