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 computation uses percentile-based datasets and weighted averages to determine the acceptable transfer pricing range. Arm's length price for an international transaction or specified domestic transaction is determined from an ascending dataset of comparable uncontrolled transactions, including weighted averages where data span more than one year. Where six or more entries exist, an arm's length range is formed between the thirty-fifth and sixty-fifth percentiles; a price within that range is treated as the arm's length price, and a price outside the range is taken at the median. If the percentile range does not apply, the arithmetical mean of the dataset applies, subject to the prescribed tolerance band.
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Provisions expressly mentioned in the judgment/order text.
Arm's length price computation uses percentile-based datasets and weighted averages to determine the acceptable transfer pricing range.
Arm's length price for an international transaction or specified domestic transaction is determined from an ascending dataset of comparable uncontrolled transactions, including weighted averages where data span more than one year. Where six or more entries exist, an arm's length range is formed between the thirty-fifth and sixty-fifth percentiles; a price within that range is treated as the arm's length price, and a price outside the range is taken at the median. If the percentile range does not apply, the arithmetical mean of the dataset applies, subject to the prescribed tolerance band.
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