person, being the assessee, has entered into an international transaction or specified domestic transaction in any previous year, and the Assessing Officer considers it necessary ... transaction or specified domestic transaction referred to in sub-section (1). (2A) Where any other international transaction other than an international transaction referred under
under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB ... failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions
Section 92BA in The Income Tax Act, 1961
92BA. Meaning of specified domestic transaction.
- For the purposes of this section and sections ... specified domestic transaction" in case of an assessee means any of the following transactions, not being an international transaction, namely: - (i) [***] (ii) any transaction referred
international transactions or specified domestic
transactions involving transfer of unique intangibles or in
multiple international transactions or specified domestic
transactions which are so interrelated that ... domestic transaction ;
(e) transactional net margin method, by which,--
(i) the net profit margin realised by the enterprise
from an international transaction or a specified
uncontrolled transaction shall be comparable
to an international transaction or a specified domestic
transaction if--
(i) none of the differences, if any, between the transactions ... international transaction or the specified domestic
transaction and the uncontrolled transaction and between
the enterprises entering into such transactions;
(e) the extent to which reliable
international transaction
[or the specified domestic transaction] and the comparable
uncontrolled transactions, or between the enterprises
entering into such transactions, which could materially
affect such ... international transaction [or the specified domestic
transaction] and the uncontrolled transaction and between
the enterprises entering into such transactions;
(e) the extent to which reliable
from the 1st day of April, 2013, namely: - '92BA. Meaning of specified domestic transaction. - For the purposes of this Section and sections ... specified domestic transaction" in case of an assessee means any of the following transactions, not being an international transaction, namely: - (i) any expenditure in respect
international
transaction or specified domestic transaction].--(1)
Every person who has entered into an [international
transaction or specified domestic transaction] shall keep
and maintain such ... entering into [international transaction or
specified domestic transaction].--Every person who has
entered into an [international transaction or specified
domestic transaction] during a previous year
Sony Ericsson Mobile Communications ... vs Commissioner Of Income Tax ??? Iii on 16 March, 2015
Author
section 92F and shall, for the purposes of a specified domestic transaction, include a unit, or an enterprise, or an undertaking or a business ... transaction; (ab) "uncontrolled transaction" means a transaction between enterprises other than associated enterprises, whether resident or non-resident; (ii) in relation to a specified domestic
