Section 94A(2)(ii)

(ii) any transaction in the nature of purchase, sale or lease of tangible or intangible property o r provision of service or lending or borrowing money or any other transaction having a bearing on the profits, income, losses or assets of the assessee including a mutual agreement or arrangement for allocation or apportionment of, or any contribution to, any cost or expense incurred or to be incurred in connection with a benefit, service or facility provided or to be provided by or to the assessee shall be deemed to be an international transaction within the meaning of section 92B , and the provisions of sections 92, 92A, 92B, 92C except the second proviso to sub -section