https://www.taxtmi.com/caselaws?id=347758 Transactions with an Indian resident company did not become an international transaction merely because they were routed through a USA branch, since section 92B(1) requires an associated enterprise transaction involving a non-resident element. General Woods and Veneers Ltd. was also not proved to be an associated enterprise under section 92A because the Revenue failed to establish the statutory deeming conditions on evidence; common control, price influence, and threshold-based tests under clauses (h) and (j) could not be satisfied by aggregation or assumption. The transfer pricing adjustment therefore could not stand, and the connected interest grounds fell away with the deletion of the addition. en-us Wed, 16 Aug 2017 00:00:00 +0530 Fri, 07 Nov 2025 18:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=347758 Transactions with an Indian resident company did not become an international transaction merely because they were routed through a USA branch, since section 92B(1) requires an associated enterprise transaction involving a non-resident element. General Woods and Veneers Ltd. was also not proved to be an associated enterprise under section 92A because the Revenue failed to establish the statutory deeming conditions on evidence; common control, price influence, and threshold-based tests under clauses (h) and (j) could not be satisfied by aggregation or assumption. The transfer pricing adjustment therefore could not stand, and the connected interest grounds fell away with the deletion of the addition. Case-Laws Income Tax Wed, 16 Aug 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=347758