Part DCA - Safe Harbour Rules for income referred to in clause (i) of sub-section (1) of section 9 chargeable to tax under the head (From Rule 10TI to Rule 10TIC)
Arm's length price determination uses comparable uncontrolled transactions and relevant facts as an alternative transfer pricing method. Other method of determination of arm's length price permits, for international transactions and specified domestic transactions, any method that determines arm's length price by reference to the price charged or paid, or that would have been charged or paid, in the same or similar uncontrolled transaction between non-associated enterprises under similar circumstances. The method must take into account all relevant facts and serves as an alternative transfer pricing mechanism based on comparable uncontrolled dealings.
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 determination uses comparable uncontrolled transactions and relevant facts as an alternative transfer pricing method.
Other method of determination of arm's length price permits, for international transactions and specified domestic transactions, any method that determines arm's length price by reference to the price charged or paid, or that would have been charged or paid, in the same or similar uncontrolled transaction between non-associated enterprises under similar circumstances. The method must take into account all relevant facts and serves as an alternative transfer pricing mechanism based on comparable uncontrolled dealings.
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