There are two fundamental tests to conclude whether TPR apply to a particular entity and transaction :
For a Transaction to be an international transaction, it should satisfy the following two conditions cumulatively :
Also various types of transactions like purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, capital financing, including any type of long-term or short-term borrowing, lending or guarantee, purchase or sale of marketable securities or any type of advance, payments or deferred payment or receivable or any other debt arising during the course of business etc are covered.
The concept of deemed an associated enterprise has also been incorporated in S. 92A (2) which provide that two enterprises shall be deemed to be associated enterprises if, at any time during the previous year :
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