Under section 163(1) of the Income-tax Act, 2025, what residence condition must be met for a transaction between two associated enterprises to be an international transaction?

Section 163(1) of the Income-tax Act, 2025 defines an international transaction as one between two or more associated enterprises, one of which is necessarily a non-resident. It is enough that either or both are non-residents, and residence, not the place of incorporation, is the test; transactions between two residents may instead be specified domestic transactions under section 164.