https://www.taxtmi.com/caselaws?id=800415 Transfer-pricing of delayed foreign-currency receivables requires an imputed interest rate that reflects prevailing foreign-currency lending conditions. Where receivables are denominated in foreign currency, a corresponding foreign-currency benchmark is appropriate rather than a domestic borrowing rate. LIBOR, as an international banking benchmark at the relevant time, supports use of the six-month LIBOR rate plus 200 basis points where no material demonstrates that this margin is perverse or inconsistent with prevailing rates. The rate determination is essentially factual and does not ordinarily raise a substantial question of law. en-us Tue, 29 Sep 2026 00:00:00 +0530 Tue, 06 Oct 2026 08:13:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800415 Transfer-pricing of delayed foreign-currency receivables requires an imputed interest rate that reflects prevailing foreign-currency lending conditions. Where receivables are denominated in foreign currency, a corresponding foreign-currency benchmark is appropriate rather than a domestic borrowing rate. LIBOR, as an international banking benchmark at the relevant time, supports use of the six-month LIBOR rate plus 200 basis points where no material demonstrates that this margin is perverse or inconsistent with prevailing rates. The rate determination is essentially factual and does not ordinarily raise a substantial question of law. Case-Laws Income Tax Tue, 29 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800415