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 pricing rules define the methods, comparability factors, and data standards for transfer pricing analysis. Determination of arm's length price for international transactions and specified domestic transactions is made by the most appropriate method under the transfer pricing framework, including the comparable uncontrolled price, resale price, cost plus, profit split, transactional net margin, and any other prescribed method. The rule prescribes method-specific adjustments for differences that materially affect price, gross profit, cost, or net profit, and requires comparability to be assessed by reference to the property or services, functions performed, assets, risks, contractual terms, market conditions, and the relevant data period for analysis.
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 pricing rules define the methods, comparability factors, and data standards for transfer pricing analysis.
Determination of arm's length price for international transactions and specified domestic transactions is made by the most appropriate method under the transfer pricing framework, including the comparable uncontrolled price, resale price, cost plus, profit split, transactional net margin, and any other prescribed method. The rule prescribes method-specific adjustments for differences that materially affect price, gross profit, cost, or net profit, and requires comparability to be assessed by reference to the property or services, functions performed, assets, risks, contractual terms, market conditions, and the relevant data period for analysis.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.