https://www.taxtmi.com/caselaws?id=371292 Amounts routed through an associated enterprise for acquisition of film distribution rights were treated as part of a single back-to-back commercial arrangement, not as financing or lending in substance. The enterprise acted only as a conduit, with funds immediately remitted to the third party and later routed back without any meaningful retention. On these facts, the Explanation to Section 92B, including references to capital financing, borrowings, advances, payments and receivables, was held not to apply. The arrangement did not result in diversion of income or any taxable benefit to the associated enterprise, so Chapter X transfer pricing provisions were not attracted. en-us Mon, 26 Nov 2018 00:00:00 +0530 Sat, 01 Dec 2018 14:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=371292 Amounts routed through an associated enterprise for acquisition of film distribution rights were treated as part of a single back-to-back commercial arrangement, not as financing or lending in substance. The enterprise acted only as a conduit, with funds immediately remitted to the third party and later routed back without any meaningful retention. On these facts, the Explanation to Section 92B, including references to capital financing, borrowings, advances, payments and receivables, was held not to apply. The arrangement did not result in diversion of income or any taxable benefit to the associated enterprise, so Chapter X transfer pricing provisions were not attracted. Case-Laws Income Tax Mon, 26 Nov 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=371292