International transaction definition broadened: third-party dealings treated as international transactions when an enterprise or associated enterprise is non-resident. The amendment expands the deeming rule in section 92B so that a transaction between an enterprise and an unrelated third party will be treated as an international transaction where the enterprise or the associated enterprise or both are non-residents, irrespective of the residential status of the third party, thereby subjecting such transactions to transfer pricing rules when terms are determined in substance by an associated enterprise.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
International transaction definition broadened: third-party dealings treated as international transactions when an enterprise or associated enterprise is non-resident.
The amendment expands the deeming rule in section 92B so that a transaction between an enterprise and an unrelated third party will be treated as an international transaction where the enterprise or the associated enterprise or both are non-residents, irrespective of the residential status of the third party, thereby subjecting such transactions to transfer pricing rules when terms are determined in substance by an associated enterprise.
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