Mere use of foreign word is immaterial to fall within ambit of international transaction

Organon (India) Pvt. Ltd Vs PCIT (Calcutta High Court) Calcutta High Court held that mere usage of foreign word does not make it automatic to fall within the ambit of an international transaction. Facts- This appeal filed by the revenue u/s. 260A of the Income Tax Act, 1961 (the ‘Act’ ) is directed against the order dated 12th October 2018 passed by the Income Tax Appellate Tribunal for A.Y. 2012-13 and 2013-14. Revenue contested that ITAT has erred in deleting the addition of INR 7,07,55,565/- of AY 2012-13 and INR 15,60,70,670/- for AY 2013-14 made upward adjustment on account of ALP of ...