
Case Law Analysis
|Income Tax Appellate Tribunal
Section 92B Income Tax Act | Notional Interest on Delayed Trade Receivables from AEs is an International Transaction: ITAT Bangalore Reduces Rate to LIBOR+200
ITAT Bangalore ruled that delayed trade receivables from associated enterprises constitute an international transaction under Section 92B, warranting notional interest adjustment. However, it reduced the applicable rate from LIBOR+450 to LIBOR+200 basis points, setting a precedent for transfer pricing disputes involving deferred payments.