TP: Unilateral action without agreement or understanding cannot be termed as a transaction

Perfetti Van Melle India Pvt Ltd. Vs ACIT (ITAT Delhi)

Thus, in order to be characterized as an ‘international transaction’, it would have to be demonstrated that the transaction arose pursuant to an arrangement, understanding or action in concert. A ‘transaction’, per se involves a bilateral arrangement or contract between the parties. Unilateral action by one of the parties, without any binding obligation, in absence of a mutual understanding or contract, could not be termed as a ‘transaction’. A unilateral action, therefore, could not be

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