AAR held that the transaction between non-resident entities was an international transaction, within the meaning of Explanation (ie) below section 92B , as admittedly the share transfer transaction was a sequel to business reorganization. The transaction related to shares in the Indian company or asset situated in India and in terms of section 9(1)(i) read with Explanation 5 the transaction would give rise to income deemed to accrue or arise in India. Proposed  transaction would liable to capital gains tax in the hands of transferor and liable to deduct tax under section 195 of the Act and the  applicant could seek set-off of Swiss taxes, if any, under article 23(1)(b) of the Double Taxation Avoidance Agreement between India and Switzerland.