Arm's length price rule deems actual transaction price as arm's length where variation falls within a de minimis threshold. The amendment prescribes that when the most appropriate method yields more than one price, the arm's length price is the arithmetical mean of those prices, and further provides that where variation between that determined arm's length price and the actual transaction price falls within a small permitted variation, the actual transaction price shall be deemed to be the arm's length price.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Arm's length price rule deems actual transaction price as arm's length where variation falls within a de minimis threshold.
The amendment prescribes that when the most appropriate method yields more than one price, the arm's length price is the arithmetical mean of those prices, and further provides that where variation between that determined arm's length price and the actual transaction price falls within a small permitted variation, the actual transaction price shall be deemed to be the arm's length price.
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