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Income Tax - Highlights / Catch Notes

Home Highlights June 2022 Year 2022 This

TP Adjustment made on account of interest chargeable on ...

Income Tax

June 20, 2022

TP Adjustment made on account of interest chargeable on outstanding receivables - applying LIBOR rates - adoption of SBI prime lending rate @14.45% is definitely excessive and is not in order. In our considered opinion, applying LIBOR rates plus two basis points would be a reasonable rate of interest which should be adopted for benchmarking the international transaction of interest on outstanding receivables. - AT

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  1. TP Adjustment - delayed receivables from AE - re-characterizing the delay in receipt of receivables as unsecured loan, the AO computed interest by applying rate of 4.33%...

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  6. TPA - international transaction - any further adjustment only on the basis of the outstanding receivables would have distorted the picture and recharacterised the transaction

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