Transfer of Call Center Business to Indian Entity HWP Deemed International Transaction u/s 92B(1) of Income Tax Act.

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....TPA - to avoid the tax liability in India, the call centre business was though apparently transferred to HWP (India) but the real transaction of sale and purchase is between the assessee and HTIL/HWL Group. Therefore, the transaction being between the assessee and its non resident AEs would constitute the international transaction in terms of section 92B(1) - AT....