https://www.taxtmi.com/highlights?id=96299 The dispute concerns whether a domestic divestment of a support services business between two resident associated enterprises can be treated as an international transaction or a deemed international transaction under transfer pricing Chapter X. The tribunal reasoned that section 92B(2) requires a transaction with a person other than an associated enterprise, so a transaction between two AEs does not satisfy that statutory gateway; the respondent's reliance on substance over form and alleged prior non-resident influence was rejected as immaterial to the statutory prerequisite. Consequently, section 92B(2) did not apply and the transaction was not a deemed international transaction, allowing the appeal. en-us Fri, 23 Jan 2026 09:11:01 +0530 Fri, 23 Jan 2026 09:11:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96299 The dispute concerns whether a domestic divestment of a support services business between two resident associated enterprises can be treated as an international transaction or a deemed international transaction under transfer pricing Chapter X. The tribunal reasoned that section 92B(2) requires a transaction with a person other than an associated enterprise, so a transaction between two AEs does not satisfy that statutory gateway; the respondent's reliance on substance over form and alleged prior non-resident influence was rejected as immaterial to the statutory prerequisite. Consequently, section 92B(2) did not apply and the transaction was not a deemed international transaction, allowing the appeal. Highlights Income Tax Fri, 23 Jan 2026 09:11:01 +0530 https://www.taxtmi.com/highlights?id=96299