reported the transaction as international
transaction but never challenged its wrong pleadings before TPO by
moving an application showing actual nature of transaction; that since ... deemed international transaction; that
the assessee company itself has filed form 3CEB for treating the royalty
payment as international transaction but back out thereafter
above, no income is arising out of such
alleged international / deemed international transaction, and therefore,
provisions of S.92 of the Act could not have ... transaction between the HO and APL
and JPL, the transaction between appellant and APL and JPL is a deemed
international transaction
international transaction.
14.2. Coming a step ahead of actual international transaction as per section 92B(1) , the
ld. counsel submitted that the legislature also deems ... only international transactions can be considered within the purview of the
Chapter X of the Act . Unless a transaction is an international transaction within
from an international
transaction including any expenditure arising from an international transaction but it cannot
determine the 'quantum' of international transaction or extent ... only international transactions can be considered within the
purview of the Chapter X of the Act . Unless a transaction is an international
transaction within
Transactional Net Margin Method for
benchmarking the transaction of import of finished
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Nivea India Private Limited
goods and deemed international transactions, erred ... international transaction. 928.(1) For the purposes
of this section and sections 92 , 92C , 92D and
92E ,"international transaction" means a transaction
between
transaction. Consequently, the transaction
between the assessee and Lionheart, being a transaction between
two resident associated enterprises, cannot be deemed to be an
international transaction ... hold that the impugned transaction is not an
international transaction under section 92B(1) and cannot be
deemed so under section 92B(2) , the very
transaction. Consequently, the transaction
between the assessee and Lionheart, being a transaction between
two resident associated enterprises, cannot be deemed to be an
international transaction ... hold that the impugned transaction is not an
international transaction under section 92B(1) and cannot be
deemed so under section 92B(2) , the very
from international
transactions having regard to arm's length price. It lays down that "Any
income arising from an international transaction shall ... fulfilled before a transaction can be said to be an
"International Transaction" viz., :-
(1) Transaction should be between two or more Associated Enterprises
international transaction.
92B. (1) For the purposes of this section and sections 92 , 92C , 92D and 92E ,
"international transaction" means a transaction between ... that for a transaction to be
characterised as an international transaction, the same has to be viz. (i) a specified transaction
between two or more
total income of the Appellant
in relation to the deemed international transactions pertaining to
sale of goods and re-determined the Arm's Length ... facts
in not appreciating that goods sold under the arrangement of
deemed international transaction does not make the transacting
party as associated enterprise within
