Meaning of international transaction.

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....ncludes- (a) the purchase, sale, transfer, lease or use of tangible property, including building, transportation vehicle, machinery, equipment, tools, plant, furniture, commodity or any other article, product or thing; (b) the purchase, sale, transfer, lease or use of intangible property, including the transfer of ownership or the provision of use of rights regarding land use, co....

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....ncy, scientific research, legal or accounting service; (e) a transaction of business restructuring or reorganisation, entered into by an enterprise with an associated enterprise, irrespective of the fact that it has any bearing on the profit, income, losses or assets of such enterprises at the time of the transaction or at any future date; (f) a mutual agreement or arrangement be....

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.... relevant transaction are determined, in substance, between such other person and the associated enterprise, and the enterprise or the associated enterprise or both of them are non-residents, irrespective of whether the other person is a non-resident or not. (3) The expression "intangible property" shall include:- (a) marketing related intangible assets, such as, trademarks, trade n....

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....customer relationship, open purchase orders; (g) contract related intangible assets, such as, favourable supplier, contracts, licence agreements, franchise agreements, non-compete agreements; (h) human capital related intangible assets, such as, trained and organised work force, employment agreements, union contracts; (i) location related intangible assets, such as, leas....