Assessee was engaged in the business of providing services of EPC in the field of petrochemical, oil and gas, fertilizers, instrumentation and electrical erection amongst others to its AE. TPO made an adjustment by charging notional interest on delayed recovery of export receivables from its AE. TPO applied interest rate at 12.25% i.e. SBI PLR. Tribunal held that interest chargeable on delayed recovery of export receivables and expenses from AE’s should be taken at LIBOR rates thereby relying on CIT v .Tata Autocomp Systems Ltd. (2015 374 ITR 516 (Bom.) (HC). Appeal of revenue was dismissed. (AY. 2009-10)