That on the amendment to section 92B of the Income-tax Act, 1961, with retrospective effect from April 1, 2002 it was not open for the assessee to agitate the question whether or not the interest on outstanding receivables was an international transaction requiring separate benchmarking. That, the ends of justice would be met by accepting the interest rate on similar foreign currency receivables and advances as LIBOR + 200 points.  that the interests of justice would be met by restoring the issue of adjustments for global and regional management overhead allocation fee to the file of the Assessing Officer for fresh factual verification as per law in view of the need for the assessee to file the additional documentary evidence in support of its claim. The assessee was to submit all the relevant material before the Assessing Officer. (AY. 2018-19)