https://www.taxtmi.com/caselaws?id=247590 Transactions between the assessee, its Indian permanent establishment and joint ventures were held not to be international transactions under section 92B(2) because the dealings were between resident entities for Indian tax purposes and the business decisions and execution occurred in India. As the essential non-resident element required for transfer pricing provisions was absent, the transfer pricing adjustment could not be sustained. The earlier jurisdictional view on the same assessee and issue was followed, and the Revenue's challenge to deletion of the adjustment was rejected. en-us Tue, 29 Apr 2014 00:00:00 +0530 Fri, 16 May 2014 13:10:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=247590 Transactions between the assessee, its Indian permanent establishment and joint ventures were held not to be international transactions under section 92B(2) because the dealings were between resident entities for Indian tax purposes and the business decisions and execution occurred in India. As the essential non-resident element required for transfer pricing provisions was absent, the transfer pricing adjustment could not be sustained. The earlier jurisdictional view on the same assessee and issue was followed, and the Revenue's challenge to deletion of the adjustment was rejected. Case-Laws Income Tax Tue, 29 Apr 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=247590