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| The Tax Publishers2019 TaxPub(DT) 2441 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
In order to benchmark interest on overdue receivables by assessee as a result of export goods LIBOR rate of currency of invoice raised plus suitable basis points had to be considered in stead of domestic PLR.
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Transfer pricing - Determination of ALP - Interest on overdue receivables as a result of export of goods to AE -
TPO suggested ALP adjustment on account of interest on overdue receivables as a result of export of goods to AE by considering domestic PLR as the arm's length interest rate.Held: TPO was directed to benchmark impugned transaction applying LIBOR rate of currency of invoice raised plus suitable basis points.
Followed:CIT v. Cotton Naturals (I) (P) Ltd. (2015) 276 CTR 445 (Del) : 2015 TaxPub(DT) 1361 (Del-HC).
REFERRED :
FAVOUR : Partly in assessee favour.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 14A Section 8D(2)(iii)
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