Tax alert: Special bench of ITAT analysed applicability of TP between HO and PO has been saved
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Tax alert: Special bench of ITAT analysed applicability of TP between HO and PO
24 December 2024
The Special bench of Ahmedabad Tribunal has held that a transaction between an Indian project office (‘PO, Branch, PE’) and a foreign head office (‘HO’) is a transaction between two distinct non-resident enterprises and, therefore, constitutes an ‘international transaction’ within the meaning of section 92B of the I-T Act.
