2018 (3) TMI 1849

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..... espondent : Mr. Tejveer Singh ORDER P.C: This Appeal under Section 260A of the Income Tax Act, 1961 (the Act), challenges the order dated 28th August, 2014 passed by the Income Tax Appellate Tribunal (the Tribunal). The impugned order dated 28th August, 2014 is in respect of Assessment Year 200910. 2 Revenue urges only the following question of law, for our consideration: "Whether the Trib .....

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..... ppellantAssessee to its Associated Enterprises (AE) would be an International Transactions hit by the provisions of Chapter X of the Act. In terms of the Explanation to Section 92(B) of the Act, loans/ Advances to AE is an International Transactions. Therefore, the interest income earned on such loans and advances has to be reworked to determine the Arms Length Price (ALP). Thus, upholding the enh .....

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..... Act was introduced w.e.f. Assessment Year 200203, the Explanatory Notes to the Finance Act, 2001 explained its objectives as under:" 55.4:The newly substituted section 92 provides that income arising from an international transactions between persons shall, be computed having regard to arm's length price. Any expenses or outgoing is an international transactions is also to be computed havi .....

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