Money routed through AE by assessee to acquire distributorship was not an international transaction

KSS Limited (formerly known as K Sera Productions Ltd.) Vs Pr. CIT (Bombay High Court)

Conclusion: Where the money was routed through AE by the assessee for the purpose of acquisition of distributorship, the back to back agreements, the contents thereof and most significantly, the fact that neither at the point of payment nor at the point of refund of money, AE retained the same for any significant period of time, the transaction did not result into diversion of income of assessee to its AE and did not give

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