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 documentation requires detailed records of transactions, comparability analysis, supporting evidence, and long-term retention. Documentation and information under section 92D must be maintained for international transactions and specified domestic transactions, covering ownership structure, group profile, business description, transaction terms, functions, risks, assets, comparability analysis, selection and application of the arm's length price method, working papers, assumptions, price negotiations, transfer-price adjustments, and other relevant information. The rule also provides a threshold-based exception for international transactions, a modified set for eligible specified domestic transactions, requirements for authentic supporting documents, contemporaneous maintenance, renewal only on significant change, and retention for eight years.
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 documentation requires detailed records of transactions, comparability analysis, supporting evidence, and long-term retention.
Documentation and information under section 92D must be maintained for international transactions and specified domestic transactions, covering ownership structure, group profile, business description, transaction terms, functions, risks, assets, comparability analysis, selection and application of the arm's length price method, working papers, assumptions, price negotiations, transfer-price adjustments, and other relevant information. The rule also provides a threshold-based exception for international transactions, a modified set for eligible specified domestic transactions, requirements for authentic supporting documents, contemporaneous maintenance, renewal only on significant change, and retention for eight years.
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