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: select and apply the most appropriate transfer pricing method with comparability adjustments. Determination of the arm's length price under section 92C requires selection of the most appropriate method among Comparable Uncontrolled Price, Resale Price, Cost Plus, Profit Split and Transactional Net Margin (and any method in rule 10AB). Each method prescribes identification of comparable uncontrolled transactions and specific adjustments for functional, contractual and market differences. Comparability is assessed by property/service characteristics, functions/assets/risks, contractual allocation of responsibilities, and prevailing market conditions. Data should primarily relate to the financial year of the transaction, with limited prior-year data and specified exceptions for certain methods and timing of available data.
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: select and apply the most appropriate transfer pricing method with comparability adjustments.
Determination of the arm's length price under section 92C requires selection of the most appropriate method among Comparable Uncontrolled Price, Resale Price, Cost Plus, Profit Split and Transactional Net Margin (and any method in rule 10AB). Each method prescribes identification of comparable uncontrolled transactions and specific adjustments for functional, contractual and market differences. Comparability is assessed by property/service characteristics, functions/assets/risks, contractual allocation of responsibilities, and prevailing market conditions. Data should primarily relate to the financial year of the transaction, with limited prior-year data and specified exceptions for certain methods and timing of available data.
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