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of <h1>Rules for determining arm's length price: prescribed methods, averaging or tolerance, tax authority determination after show-cause</h1> The provision prescribes how the arm's length price (ALP) for international or specified domestic transactions is to be determined by the most appropriate method from listed methods (comparable uncontrolled price, resale price, cost plus, profit split, transactional net margin or other prescribed methods), with rules for application and, where multiple prices arise, taking the arithmetic mean or, subject to notified tolerance, treating the actual transaction price as ALP. The tax authority may determine ALP during assessment if records, reliability or information are inadequate, after giving a show-cause opportunity; resulting income adjustments exclude specified deductions and may not trigger recomputation of a related associated enterprise's income in certain cases.
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