Section 92C and 260A of the Income Tax Act, 1961 — Transfer Pricing — Computation of arms length price — No substantial question of law arises for consideration as extension of credit beyond the normal period of 60 days by the assessee to its AE is in substance granting loan to the latter so as to enjoy the funds and therefore the order of the Tribunal computing the notional interest on such extended credit at LIBOR rates as the rate prevailing in the country where the loan is received by the AE cannot be faulted — Pr Commissioner of Income tax vs. Technimont P Ltd [2018] 304 CTR (Bombay) 145