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of <h1>Understanding Arm's Length Price Determination: Section 92C Methods for Fair Pricing in International Transactions</h1> The determination of arm's length price under section 92C of the Income Tax Act involves various methods to ensure fair pricing in international or specified domestic transactions. These methods include the comparable uncontrolled price method, resale price method, cost plus method, profit split method, and transactional net margin method. Each method involves specific calculations and adjustments to account for differences in transactions and ensure comparability. The rules also outline criteria for assessing comparability, such as transaction characteristics, functions performed, contractual terms, and market conditions. Data from the current financial year and up to two years prior may be used for analysis, with specific provisions for transactions after April 1, 2014.
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