Micro Ink Ltd. v. ACIT

157 ITD 132Income Tax Appellate Tribunal2016#1881 most cited

What is Micro Ink Ltd. v. ACIT authority for?

Issuance of corporate guarantees does not constitute an international transaction under section 92B, particularly for guarantees provided before the 2012 amendment. Such guarantees are considered shareholder activities or quasi-capital and do not impact enterprise profits, income, losses, or assets.

61

judgments rely on this decision, according to BharatTax’s citation analysis of 366,418 Indian tax judgments — from 2016 to 2025.

Also referred to as

Micro Ink Ltd. v. ACIT · 157 ITD 132 · section 92B · corporate guarantee · international transaction · shareholder activity · quasi-capital · transfer pricing adjustment · 2012 amendment

Also reported as

88 Taxmann.com 338

Sections most often in play

Section 92BSection 143(3)Section 147Section 148Section 37(1)Section 140A(3)Section 14ASection 250

Issues it is cited on

section 92f(v)section 92b(1)section 45(2)section 92f(ii)section 43dcorporate guaranteesection 92fsection 92bsection 140asection 92(1)minimum alternate taxproject completion method

Judgments citing Micro Ink Ltd. v. ACIT

The Addl. CIT, Range-1, Ahmedabad vs. M/S. Adani Enterprises Ltd., Ahmedabad

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

ITA 2531/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad12 Feb 2019AY 2010-11
Section 143(3)Section 14ASection 3

…er is also not satisfied with the quantum relief given by the CIT(A) and is in appeal before us. 51. We find that this issue is now covered, in favour of the assessee, by a series of decisions in various cases, including in the case of Micro Ink Ltd Vs ACIT (157 ITD 132), analysed the issue in great detail and taken note of decisions by various coordinate benches, and then come to the conclusion that issuance of corporate guarantees does not constitute an international transaction with the meanings of section 92B. Learned representatives fairly agree that the issue is thus covered, in favour of the assessee and…

Adani Enterprises Ltd., Ahmedabad vs. The Addl. CIT, Range-1, Ahmedabad

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

ITA 2305/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad12 Feb 2019AY 2010-11
Section 143(3)Section 14ASection 3

…er is also not satisfied with the quantum relief given by the CIT(A) and is in appeal before us. 51. We find that this issue is now covered, in favour of the assessee, by a series of decisions in various cases, including in the case of Micro Ink Ltd Vs ACIT (157 ITD 132), analysed the issue in great detail and taken note of decisions by various coordinate benches, and then come to the conclusion that issuance of corporate guarantees does not constitute an international transaction with the meanings of section 92B. Learned representatives fairly agree that the issue is thus covered, in favour of the assessee and…

Dy.Commissioner of Income Tax, Circle-1(1)(1), Ahmedabad vs. M/S. Adani Port & Special Economic Zone Ltd., Ahmedabad

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

ITA 3482/AHD/2014[2010-11]Status: DisposedITAT Ahmedabad12 Feb 2019AY 2010-11
Section 143(3)Section 80Section 80I

…l on record and duly considered facts of the case in the light of the applicable legal position. 22. We find that this issue is now covered, in favour of the assessee, by a series of decisions in various cases, including in the case of Micro Ink Ltd Vs ACIT (157 ITD 132), analysed the issue in great detail and taken note of decisions by various coordinate benches, and then come to the conclusion that issuance of corporate guarantees does not constitute an international transaction with the meanings of section 92B. Learned representatives fairly agree that the issue is thus covered, in favour of the assessee and…

Dy. Commissioner of Income Tax, Circle-1(1)(1), Ahmedabad vs. M/S. Adani Port & Special Economic Zone Ltd., Ahmedabad

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

ITA 3481/AHD/2014[2009-10]Status: DisposedITAT Ahmedabad12 Feb 2019AY 2009-10
Section 143(3)Section 80Section 80I

…l on record and duly considered facts of the case in the light of the applicable legal position. 22. We find that this issue is now covered, in favour of the assessee, by a series of decisions in various cases, including in the case of Micro Ink Ltd Vs ACIT (157 ITD 132), analysed the issue in great detail and taken note of decisions by various coordinate benches, and then come to the conclusion that issuance of corporate guarantees does not constitute an international transaction with the meanings of section 92B. Learned representatives fairly agree that the issue is thus covered, in favour of the assessee and…

Dy.Commissioner of Income Tax, Circle-1(1)(1), Ahmedabad vs. M/S. Adani Enterprises Ltd., Ahmedabad

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

ITA 3480/AHD/2014[2009-10]Status: DisposedITAT Ahmedabad12 Feb 2019AY 2009-10
Section 143(3)Section 14ASection 3

…er is also not satisfied with the quantum relief given by the CIT(A) and is in appeal before us. 51. We find that this issue is now covered, in favour of the assessee, by a series of decisions in various cases, including in the case of Micro Ink Ltd Vs ACIT (157 ITD 132), analysed the issue in great detail and taken note of decisions by various coordinate benches, and then come to the conclusion that issuance of corporate guarantees does not constitute an international transaction with the meanings of section 92B. Learned representatives fairly agree that the issue is thus covered, in favour of the assessee and…

Adani Enterprises Ltd., Ahmedabad vs. The Addl. CIT, Range-1, Ahmedabad

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

ITA 3321/AHD/2014[2009-10]Status: DisposedITAT Ahmedabad12 Feb 2019AY 2009-10
Section 143(3)Section 14ASection 3

…er is also not satisfied with the quantum relief given by the CIT(A) and is in appeal before us. 51. We find that this issue is now covered, in favour of the assessee, by a series of decisions in various cases, including in the case of Micro Ink Ltd Vs ACIT (157 ITD 132), analysed the issue in great detail and taken note of decisions by various coordinate benches, and then come to the conclusion that issuance of corporate guarantees does not constitute an international transaction with the meanings of section 92B. Learned representatives fairly agree that the issue is thus covered, in favour of the assessee and…

The DCIT, Circle-1, Ahmedabad vs. Adani Enterprises Ltd., Ahmedabad

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

ITA 1918/AHD/2012[2008-09]Status: DisposedITAT Ahmedabad12 Feb 2019AY 2008-09
Section 143(3)Section 14ASection 3

…er is also not satisfied with the quantum relief given by the CIT(A) and is in appeal before us. 51. We find that this issue is now covered, in favour of the assessee, by a series of decisions in various cases, including in the case of Micro Ink Ltd Vs ACIT (157 ITD 132), analysed the issue in great detail and taken note of decisions by various coordinate benches, and then come to the conclusion that issuance of corporate guarantees does not constitute an international transaction with the meanings of section 92B. Learned representatives fairly agree that the issue is thus covered, in favour of the assessee and…

Adani Enterprises Ltd., Ahmedabad vs. The Addl.CIT., Range-1, Ahmedabad

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

ITA 1840/AHD/2012[2008-09]Status: DisposedITAT Ahmedabad12 Feb 2019AY 2008-09
Section 143(3)Section 14ASection 3

…er is also not satisfied with the quantum relief given by the CIT(A) and is in appeal before us. 51. We find that this issue is now covered, in favour of the assessee, by a series of decisions in various cases, including in the case of Micro Ink Ltd Vs ACIT (157 ITD 132), analysed the issue in great detail and taken note of decisions by various coordinate benches, and then come to the conclusion that issuance of corporate guarantees does not constitute an international transaction with the meanings of section 92B. Learned representatives fairly agree that the issue is thus covered, in favour of the assessee and…

DCIT, Circle - 7(1), Kolkata vs. M/S. Britannia Industries Limited, Kolkata

ITA 1392/KOL/2017[2011-12]Status: DisposedITAT Kolkata22 Nov 2018AY 2011-12

Bench: Shri S.S.Godara & Shri, M. Balaganesh

Section 143(3)Section 92B

…₹1,96,69,635 (supra) in all the three impugned assessment years. Suffice to say, tribunal’s various decisions i.e. Bharti Airtel Ltd. vs. ACIT (161 TTJ 428) (ITAT Delhi), Redington India Ltd. vs. ACIT (41 ITR (T) 646) (ITAT Chennai), Micro Ink Ltd. vs. ACIT (157 ITD 132) (ITAT Ahd) and Videocoon Industries Ltd. vs. ACIT (55 taxmann.com 263) (ITAT Mumbai) unanimously hold that a corporate guarantee is not an international transaction within the meaning of Section 92B of the Act. 5. Mr. Srihari vehemently contends at this stage that the relevant explanation in Sec. 92B inserted in the Act by the Finance Act 2012 c…

DCIT, Circle - 7(1), Kolkata vs. M/S. Britannia Industries Limited, Kolkata

ITA 1391/KOL/2017[2010-11]Status: DisposedITAT Kolkata22 Nov 2018AY 2010-11

Bench: Shri S.S.Godara & Shri, M. Balaganesh

Section 143(3)Section 92B

…₹1,96,69,635 (supra) in all the three impugned assessment years. Suffice to say, tribunal’s various decisions i.e. Bharti Airtel Ltd. vs. ACIT (161 TTJ 428) (ITAT Delhi), Redington India Ltd. vs. ACIT (41 ITR (T) 646) (ITAT Chennai), Micro Ink Ltd. vs. ACIT (157 ITD 132) (ITAT Ahd) and Videocoon Industries Ltd. vs. ACIT (55 taxmann.com 263) (ITAT Mumbai) unanimously hold that a corporate guarantee is not an international transaction within the meaning of Section 92B of the Act. 5. Mr. Srihari vehemently contends at this stage that the relevant explanation in Sec. 92B inserted in the Act by the Finance Act 2012 c…

DCIT, Circle - 7(1), Kolkata vs. M/S. Britannia Industries Limited, Kolkata

ITA 1390/KOL/2017[2009-10]Status: DisposedITAT Kolkata22 Nov 2018AY 2009-10

Bench: Shri S.S.Godara & Shri, M. Balaganesh

Section 143(3)Section 92B

…₹1,96,69,635 (supra) in all the three impugned assessment years. Suffice to say, tribunal’s various decisions i.e. Bharti Airtel Ltd. vs. ACIT (161 TTJ 428) (ITAT Delhi), Redington India Ltd. vs. ACIT (41 ITR (T) 646) (ITAT Chennai), Micro Ink Ltd. vs. ACIT (157 ITD 132) (ITAT Ahd) and Videocoon Industries Ltd. vs. ACIT (55 taxmann.com 263) (ITAT Mumbai) unanimously hold that a corporate guarantee is not an international transaction within the meaning of Section 92B of the Act. 5. Mr. Srihari vehemently contends at this stage that the relevant explanation in Sec. 92B inserted in the Act by the Finance Act 2012 c…

Sophos Technologies Private Limited, (Formerly Known As Cyberoam Technologies Private Limited), Ahmedabad vs. The Dy. CIT, Circle-4(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1565/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad16 Nov 2018AY 2012-13
Section 143(3)Section 92C

…ts of the case in the light of the applicable legal position. 6. As learned Counsel rightly points out, this issue is now covered, in favour of the assessee, by a decision of Ahmedabad Bench of this Tribunal in the case of Micro Inks Limited Vs. ACIT, [2016] 157 ITD 132 (Ahmedabad - Trib.), wherein, after taking into account Hon’ble jurisdictional High Court’s judgment in the case of Nirma Industries Ltd. Vs.. DCIT, [2006] 283 ITR 402 and the Hon’ble Delhi High Court’s judgement in the case of Sony Ericsson Mobile Corpn. (P.) Ltd. v. CIT, [2015] 374 ITR 118, the Co- ordinate bench has, inter alia, observed as un…

Gemstone Glass Pvt. Ltd., Kadi vs. The Dy. CIT, Circle-3(1)(1), Ahmedabad

In the result, appeal is allowed in the terms indicated above

ITA 414/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad23 Oct 2018AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy1. It(Tp)A No.3533/Ahd/2015 - Ay 2010-11 2. It(Tp)A No.3631/Ahd/2015 - Ay 2011-12 3. It (Tp)A No.414/Ahd/2017 - Ay 2012-13

For Appellant: Shri Suhail DuttFor Respondent: Ms. Vasundhara Upmanyu, CIT-DR
Section 143(3)Section 144CSection 154

…icable legal position. 5. As Learned Counsel for the assessee rightly points out, the issue in appeal is covered, in favour of the assessee, by a series of orders passed by the co-ordinate benches, including in the case of Micro Ink Ltd. v. Addl. CIT [(2016) 157 ITD 132 (Ahd.)] wherein the co- ordinate bench has, inter alia, observed as follows: "4. The relevant material facts, as necessary for our adjudication, are like this. The assessee before us is a leading ink manufacturer in India. The assessee has a wholly owned subsidiary in Austria, by the name of Micro Inks GmbH which, in turn, owns Micro Ink Co USA.…

Gemstone Glass Pvt. Ltd., (Successor in Pino Bisaza Glass Pvt. Ltd.), Kadi vs. The Dy.CIT, Circle-3(1)(1), Ahmedabad

In the result, appeal is allowed in the terms indicated above

ITA 3631/AHD/2015[2011-12]Status: DisposedITAT Ahmedabad23 Oct 2018AY 2011-12

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy1. It(Tp)A No.3533/Ahd/2015 - Ay 2010-11 2. It(Tp)A No.3631/Ahd/2015 - Ay 2011-12 3. It (Tp)A No.414/Ahd/2017 - Ay 2012-13

For Appellant: Shri Suhail DuttFor Respondent: Ms. Vasundhara Upmanyu, CIT-DR
Section 143(3)Section 144CSection 154

…icable legal position. 5. As Learned Counsel for the assessee rightly points out, the issue in appeal is covered, in favour of the assessee, by a series of orders passed by the co-ordinate benches, including in the case of Micro Ink Ltd. v. Addl. CIT [(2016) 157 ITD 132 (Ahd.)] wherein the co- ordinate bench has, inter alia, observed as follows: "4. The relevant material facts, as necessary for our adjudication, are like this. The assessee before us is a leading ink manufacturer in India. The assessee has a wholly owned subsidiary in Austria, by the name of Micro Inks GmbH which, in turn, owns Micro Ink Co USA.…

Gemstone Glass Pvt. Ltd., (Successor in Pino Bisaza Glass Pvt. Ltd.), Kadi vs. The Dy.CIT, Circle-3(1)(1), Ahmedabad

In the result, appeal is allowed in the terms indicated above

ITA 3533/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad23 Oct 2018AY 2010-11

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy1. It(Tp)A No.3533/Ahd/2015 - Ay 2010-11 2. It(Tp)A No.3631/Ahd/2015 - Ay 2011-12 3. It (Tp)A No.414/Ahd/2017 - Ay 2012-13

For Appellant: Shri Suhail DuttFor Respondent: Ms. Vasundhara Upmanyu, CIT-DR
Section 143(3)Section 144CSection 154

…icable legal position. 5. As Learned Counsel for the assessee rightly points out, the issue in appeal is covered, in favour of the assessee, by a series of orders passed by the co-ordinate benches, including in the case of Micro Ink Ltd. v. Addl. CIT [(2016) 157 ITD 132 (Ahd.)] wherein the co- ordinate bench has, inter alia, observed as follows: "4. The relevant material facts, as necessary for our adjudication, are like this. The assessee before us is a leading ink manufacturer in India. The assessee has a wholly owned subsidiary in Austria, by the name of Micro Inks GmbH which, in turn, owns Micro Ink Co USA.…

Bisazza India Limited, Mehsana vs. The Income Tax Officer, Ward-1(1)(3), Ahmedabad

In the result, appeal is allowed in the terms indicated above

ITA 3543/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad16 May 2018AY 2012-13
Section 143(3)Section 92C

…cable legal position. 5. As Learned Counsel for the assessee rightly points out, the issue in appeal is covered, in favour of the assessee, by a series of orders passed by the co-ordinate benches, including in the case of Micro Ink Ltd. vs. Addl. CIT [(2016) 157 ITD 132 (Ahd)] wherein the co-ordinate bench has, inter alia, observed as follows: “4. The relevant material facts, as necessary for our adjudication, are like this. The assessee before us is a leading ink manufacturer in India. The assessee has a wholly owned subsidiary in Austria, by the name of Micro Inks GmbH which, in turn, owns Micro Ink Co USA. T…

ACIT 2(1), Mumbai vs. Bombay Dyeing & Manufacturing Co, . Ltd, Mumbai

In the result, ground of appeal raised by Revenue is dismissed

ITA 6055/MUM/2014[2008-09]Status: DisposedITAT Mumbai02 Apr 2018AY 2008-09

Bench: Shri R.C. Sharma & Shri Pawan Singhacit -2(1) M/S Bombay Dyeing & Mfg. Co. Aayakar Bhavan, M.K. Road, Ltd. Neville House, J N Heredia Room No. 575, 5Th Floor, M.K. Vs. Marg, Ballard Estate, Road, Mumbai-20. Mumbai-400001 Pan:Aaact2328K (Appellant) (Respondent) M/S Bombay Dyeing & Mfg. Co. Acit -2(1) Ltd. Neville House, J N Heredia Aayakar Bhavan, M.K. Road, Marg, Ballard Estate, Mumbai-20. Vs. Mumbai-400001 Pan:Aaact2328K (Appellant) (Respondent) Acit -2(1) M/S Bombay Dyeing & Mfg. Co. Room No. 561, 5Th Floor, Ltd. Neville House, J N Heredia Vs. Aayakar Bhavan, M.K. Road, Marg, Ballard Estate, Mumbai-20. Mumbai-400001 Pan:Aaact2328K (Appellant) (Respondent) M/S Bombay Dyeing & Mfg. Co. Acit -2(1) Ltd. Neville House, J N Heredia Aayakar Bhavan, M.K. Road, Mumbai-20. Marg, Ballard Estate, Vs. Mumbai-400001 Pan:Aaact2328K (Appellant) (Respondent)

For Appellant: Shri Yogesh A. Thar with MsFor Respondent: Shri Saurabh Deshpande (DR)
Section 14ASection 253Section 254(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL, BENCH “K”, MUMBAI BEFORE SHRI R.C. SHARMA, ACCOUNTANT MEMBER AND SHRI PAWAN SINGH, JUDICIAL MEMBER ACIT -2(1) M/s Bombay Dyeing & Mfg. Co. Aayakar Bhavan, M.K. Road, Ltd. Neville House, J N Heredia Room No. 575, 5th Floor, M.K. Vs. Marg, Ballard Estate, Road, Mumbai-20. Mumbai-400001 PAN:AAACT2328K (Appellant) (Respondent) M/s Bombay Dyeing & Mfg. Co. ACIT -2(1) Ltd. Neville House, J N Heredia Aayakar Bhavan, M.K. Road, Marg, Ballard Estate, Mumbai-20. Vs. Mumbai-400001 PAN:AAACT2328K (Appellant) (Respondent) ACIT -2(1) M/s Bombay Dyeing & Mfg. Co. Room No. 561, 5th Floor,…

Addl CIT 2(1), Mumbai vs. Bombay Dyeing & Mfg Co. Ltd, Mumbai

In the result, ground of appeal raised by Revenue is dismissed

ITA 557/MUM/2012[2007-08]Status: DisposedITAT Mumbai02 Apr 2018AY 2007-08

Bench: Shri R.C. Sharma & Shri Pawan Singhacit -2(1) M/S Bombay Dyeing & Mfg. Co. Aayakar Bhavan, M.K. Road, Ltd. Neville House, J N Heredia Room No. 575, 5Th Floor, M.K. Vs. Marg, Ballard Estate, Road, Mumbai-20. Mumbai-400001 Pan:Aaact2328K (Appellant) (Respondent) M/S Bombay Dyeing & Mfg. Co. Acit -2(1) Ltd. Neville House, J N Heredia Aayakar Bhavan, M.K. Road, Marg, Ballard Estate, Mumbai-20. Vs. Mumbai-400001 Pan:Aaact2328K (Appellant) (Respondent) Acit -2(1) M/S Bombay Dyeing & Mfg. Co. Room No. 561, 5Th Floor, Ltd. Neville House, J N Heredia Vs. Aayakar Bhavan, M.K. Road, Marg, Ballard Estate, Mumbai-20. Mumbai-400001 Pan:Aaact2328K (Appellant) (Respondent) M/S Bombay Dyeing & Mfg. Co. Acit -2(1) Ltd. Neville House, J N Heredia Aayakar Bhavan, M.K. Road, Mumbai-20. Marg, Ballard Estate, Vs. Mumbai-400001 Pan:Aaact2328K (Appellant) (Respondent)

For Appellant: Shri Yogesh A. Thar with MsFor Respondent: Shri Saurabh Deshpande (DR)
Section 14ASection 253Section 254(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL, BENCH “K”, MUMBAI BEFORE SHRI R.C. SHARMA, ACCOUNTANT MEMBER AND SHRI PAWAN SINGH, JUDICIAL MEMBER ACIT -2(1) M/s Bombay Dyeing & Mfg. Co. Aayakar Bhavan, M.K. Road, Ltd. Neville House, J N Heredia Room No. 575, 5th Floor, M.K. Vs. Marg, Ballard Estate, Road, Mumbai-20. Mumbai-400001 PAN:AAACT2328K (Appellant) (Respondent) M/s Bombay Dyeing & Mfg. Co. ACIT -2(1) Ltd. Neville House, J N Heredia Aayakar Bhavan, M.K. Road, Marg, Ballard Estate, Mumbai-20. Vs. Mumbai-400001 PAN:AAACT2328K (Appellant) (Respondent) ACIT -2(1) M/s Bombay Dyeing & Mfg. Co. Room No. 561, 5th Floor,…

The Bombay Dyeing & Mfg. Co. Ltd, Mumbai vs. DCIT RG 2(1)(1), Mumbai

ITA 1716/MUM/2017[2012-13]Status: DisposedITAT Mumbai27 Oct 2017AY 2012-13

Bench: Sri Mahavir Singh, Jm & Sri N K Pradhan, Am The Bombay Dyeing & Mfg. Co. Dy. Commissioner Of Limited Income Tax, Range- Neville House, J.N. Heradia Marg, 2(1)(1), Mumbai Vs. Ballard Estate, Mumbai-400 001 Room No.561, Aayakar Pan No.Aaact2328K Bhavan, Mumbai-400 020

Section 144C(5)

…ete the impugned ALP 23 The Bombay Dyeing & Mfg. Co. Limited (A.Y:2012-13) adjustment of Rs 33,10,161. The assessee gets the relief accordingly." 17. We further notice that the decision of Ahmedabad Tribunal in the case of Micro Ink Ltd. Vs. Add. CIT [2016] 157 ITD 132 (Ahd-Trib.), which has followed the decision of Bharti Airtel (supra) held that issuance of corporate guarantees was in the nature of shareholder's activity/quasi capital, thus, could not be included in the ambit of international transaction u/s 92(1) of the Act. Further, Ahmedabad Tribunal has distinguished the decision of Hon'ble Bombay High Co…

DCIT Cir 3(3), Mumbai vs. Siro Clinpharm P.Ltd, Mumbai

In the result, appeal of the assessee is allowed

ITA 2876/MUM/2014[2009-10]Status: DisposedITAT Mumbai31 Mar 2016AY 2009-10
Section 143(3)Section 250Section 80ISection 92CSection 92C(2)Section 92C(3)

…a short while, deal with very elaborate and detailed submissions made by learned Departmental Representative, we may begin by pointing out that this issue has been dealt with in detail by decision of a coordinate bench in the case of Micro Ink vs ACIT [(2016) 176 TTJ 8 (Ahd)] wherein the coordinate bench has, inter alia, observed as follows: 21. It is only elementary that the determination of arm's length price, under the scheme of the international transfer pricing set out in the Income-tax Act, 1961, can only be done in respect of an 'international transaction'. Section 92(1) provides that, "(a)ny income arisi…