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)
Transfer pricing method selection turns on transaction facts, comparability, reliable data, and arm's length price measurement. Determination of the most appropriate method for transfer pricing under section 92C requires selection of the method best suited to the facts and circumstances of each particular international transaction or specified domestic transaction and capable of providing the most reliable measure of arm's length price. In selecting that method, regard must be had to the nature and class of the transaction, the associated enterprises involved, the functions performed, the availability and reliability of data, comparability, adjustments for differences, and the assumptions required for application of the method.
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.
Transfer pricing method selection turns on transaction facts, comparability, reliable data, and arm's length price measurement.
Determination of the most appropriate method for transfer pricing under section 92C requires selection of the method best suited to the facts and circumstances of each particular international transaction or specified domestic transaction and capable of providing the most reliable measure of arm's length price. In selecting that method, regard must be had to the nature and class of the transaction, the associated enterprises involved, the functions performed, the availability and reliability of data, comparability, adjustments for differences, and the assumptions required for application of the method.
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