https://www.taxtmi.com/caselaws?id=347758 ITAT held that transactions with the USA branch of a related Indian-incorporated company were not "international transactions" under s.92B(1) since both parties are Indian tax residents, and the application of Chapter X was erroneous. The Tribunal also found no material to establish that the other counterparty qualified as an associated enterprise under s.92A, rejecting reliance on search-record statements and concluding the AO misinterpreted the evidence. Consequently the Chapter X adjustments were set aside and the additions deleted, decision in favour of the assessee. 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 ITAT held that transactions with the USA branch of a related Indian-incorporated company were not "international transactions" under s.92B(1) since both parties are Indian tax residents, and the application of Chapter X was erroneous. The Tribunal also found no material to establish that the other counterparty qualified as an associated enterprise under s.92A, rejecting reliance on search-record statements and concluding the AO misinterpreted the evidence. Consequently the Chapter X adjustments were set aside and the additions deleted, decision in favour of the assessee. Case-Laws Income Tax Wed, 16 Aug 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=347758