The Transfer Pricing Officer made an adjustment on account of excess credit period allowed to Associated Enterprises by applying the retrospective amendment to section 92B introduced by the Finance Act, 2012. Consequently, interest under section 234B was levied for short payment of advance tax. The Tribunal held that, at the time of filing the return, the assessee could not have anticipated the subsequent retrospective amendment enlarging the scope of “international transaction”. Since the assessee had paid advance tax on the basis of the law prevailing on the date of filing the return, it could not be treated as a defaulter. The levy of interest under section 234B was therefore deleted. (AY. 2008-09).