Explain the meaning of the term "International transaction", as envisaged by section 92B of the Income-tax Act, 1961, in the context of transfer pricing provisions.

CS Professional · Advanced Tax Laws · PYQS · December 2024
Explain the meaning of the term "International transaction", as envisaged by section 92B of the Income-tax Act, 1961, in the context of transfer pricing provisions.

Answer & Explanation:

Answer 5(c) Meaning of "International transaction": Section 92B "International transaction" means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets of such enterprises, and shall include a mutual agreement or arrangement between two or more associated enterprises for the allocation or apportionment of, or any contribution to, any cost or expense incurred or to be incurred in connection with a benefit, service or facility provided or to be provided to any one or more of such enterprises.

Topics: International Taxation

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