Slump sale between Indian subsidiaries of foreign holding company not an international transaction under Income Tax Act Section 92B.

TP Adjustment Transaction of slump sale between the subsidiaries of Foreign Holding Company - To be considered as an international transaction or not - The meaning of international transaction ‘contained in section 92B of the Act is plain and clear. It does not envisage that if a resident AE is a subsidiary of a foreign holding company, the transaction between such Indian subsidiary and another Indian company would fall within the ambit of international transaction as defined u/s. 92B of the Act. - AT .....

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