Dismissing the appeal of the revenue the Court held that, Release of money in favour of Associated Enterprise with a specific purpose of acquisition of distributorship of the films from Citi Gate Trade FZE is not a case of either financing or lending or advancing of any moneys- Not International Transaction did not result in to diversion of income of the assessee to the Associated Enterprise. (AY. 2009-10)
PCIT v. KSS Ltd( 2018) 172 DTR 441/. (2019) 306 CTR 172 (Bom.) (HC)
S. 92C : Transfer pricing–Release of money in favour of Associated Enterprise with a specific purpose of acquisition of distributorship of the films from Citi Gate Trade FZE is not a case of either financing or lending or advancing of any moneys- Not International Transaction did not result in to diversion of income of the assessee to the Associated Enterprise. [S. 92, 92B, 92D, 92E]