Section 92B- Deemed international transaction- Termination of Option rights under agreement

Vodafone India Services Pvt Ltd Vs. DCIT (ITAT Ahmedabad)  97. The question that we really need to address ourselves to is whether the above arrangement constitutes an ‘international transaction’. However, before we do so, it is only appropriate that we take a look at the relevant definitions under the Income Tax Act, 1961. Section 92 B of the Act, which defines ‘international transaction’ states as follows: 92B – Meaning of international transaction (1) For the purposes of this section and sections 92, 92C, 92D and 92E, “international transaction” means a transaction between tw...