SBI rate is a local rate and LIBOR is a foreign rate, therefore, LIBOR rate should be preferred as against SBI local rate of interest. Where once transaction between assessee and A.E. was in foreign currency and transaction was an international transaction, then commercial principles in regard to international transactions are to be applied. In such circumstances, domestic prime lending rate would have no applicability and international rate fixed being LIBOR would come into play. Hence, LIBOR rate had to be considered while determining arm’s length interest rate in respect of transaction between assessee and A.E. ( ITA No. 1148/Del/2017, dt. 22.02.2019)