The deeming fiction which came to be introduced in Section 92B(2) would undisputedly have no impact or implication since sub-section (2) also speaks of the existence of a prior agreement in relation to the relevant transaction
The Delhi High Court in a recent case held that advertising, marketing, and Promotion expenditure incurred not constitute an “international transaction” under section 92F of the Income Tax Act, 1961. The appellant, raised the question of whether the Advertisement, Marketing and Promotion expenditure incurred by the respondentassessee would constitute an “international transaction” as contemplated under Section 92B read…
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