Business restructuring entered by enterprise with associated enterprise qualifies as international transaction

Dimexon Diamonds Ltd Vs ACIT (ITAT Mumbai)

ITAT Mumbai held that business restructuring entered into by an enterprise with its associated enterprise for eliminating duplicate corporate procedures falls within the ambit of “international transaction” as defined in section 92B of the Income Tax Act.

Facts- The assessee is primarily engaged in diamond manufacturing/distribution. It is a wholly owned subsidiary of Dimexon (India) Holding Pvt. Ltd. (DIHPL), which i

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