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Meaning of International Transaction

Income Tax - Transfer Pricing - International + Domestic - 04 - SECTION 92B: (1) International Transaction: The definition of international transaction includes transaction between associated enterprises in the nature of: purchase, sale, transfer, lease or use of tangible property; or purchase, sale, transfer, lease or use of intangible property; provision of services; or capital financing including lending or borrowing or guarantee; or any other transaction having a bearing on the profits, inco .....

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tion with a benefit, service, facility provided to any one or more such enterprises. Conditions: For a transaction to be an international transaction, it should satisfy the following two conditions cumulatively: It must be a transaction between two associated enterprises and At least one of the two enterprises must be a non-resident. If both the associated enterprises are non-residents, then Transfer Pricing shall apply only if income of one of the non-residents is assessable under the Indian In .....

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n, product patents (f) Customer related intangible assets, such as, Customer lists, customer contracts, (g) Contract related intangible assets, such as, Favourable supplier, contracts, (h) Human capital related intangible assets, such as, Trained and organised work force, employment agreements, (i) Location related intangible assets, such as, Leasehold interest, mineral exploitation rights, (j) Goodwill related intangible assets, such as, institutional goodwill, professional practice goodwill (k .....

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