Transaction amongst Indian PE of a foreign Co. and another resident entity isn’t an ‘International T

IT/ILT : Substance over form rule under section 92B(2) applies only when third party interposed in International Transaction between two Associated Enterprises. Transactions between resident assessee and resident AE being JV-AOP of foreign parent can't be deemed as international transaction by invoking the substance over form rule under section 92B(2). Nor can transaction between resident assessee and PE in India of foreign parent be deemed as International Transaction under section 92B(2) espec