Allocating an onshore contract by an AE to Indian affiliate is an 'International Transaction' subjec

IT/ILT: Where AE of assessee entered into four agreements with Power Grid Corporation of India Limited (PGCIL) and later on it with consent of PGCIL had assigned portion of onshore contract to assessee, assignment agreement between AE and assessee had all ingredients of an international transaction within meaning of section 92B and price paid for such transaction had to pass ALP test