Outstanding Receivables from Associated Enterprises Require Separate Benchmarking Under Section 92B with LIBOR-Based Interest Computation

The ITAT held that outstanding receivables from Associated Enterprises constitute an international transaction requiring separate benchmarking under section 92B (retrospectively amended from 01/04/2002). The Tribunal directed the AO to compute interest on delayed receivables using LIBOR + 200 basis points as per the DRP's revised direction, partially allowing the assessee's appeal. Regarding the disallowance of bonus payment deduction under section 43B made in the section 143(1) intimation, the ITAT permitted consideration of this issue within the section 143(3) proceedings despite no separate appeal having been filed against the intimation. The matter was remanded to the AO for fresh adjudication on merits, partially allowing this ground of appeal for statistical purposes. .....

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