Safe harbour rules now govern determination of specified income and arm's length pricing, covering declared transfer price or deemed income. The amendment makes determination of income under the specified source provision and computation of arm's length price under transfer pricing rules subject to safe harbour rules, and revises the Explanation to refer to the transfer price or income deemed to accrue or arise under the specified source provision as declared by the assessee.
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Provisions expressly mentioned in the judgment/order text.
Safe harbour rules now govern determination of specified income and arm's length pricing, covering declared transfer price or deemed income.
The amendment makes determination of income under the specified source provision and computation of arm's length price under transfer pricing rules subject to safe harbour rules, and revises the Explanation to refer to the transfer price or income deemed to accrue or arise under the specified source provision as declared by the assessee.
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