YASHWANT VARMA, J.
1. These two appeals pertain to Assessment Years1 2009-10 and
2012-13 and raise the question of whether the Advertisement,
AYs
Marketing and Promotion2 expenditure incurred by the respondent-
assessee would constitute an “international transaction” as
contemplated under Section 92B read along with Section 92F of the
Income Tax Act, 19613.
2. The appeals were originally admitted by us in terms of an order
dated 12 March 2024. We had on that date after hearing learned
counsels for respective sides framed the following two questions which,
according to us, arose for our consideration: –
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