Arm's length price: related party transactions must be priced and documented to reflect independent market terms. Income, expenses and apportioned costs from transactions between associated enterprises must be computed with regard to the arm's length price. Associated enterprises and international transactions are defined by participation in management, control or capital and by specified deeming tests. Arm's length price is determined by the most appropriate method from a prescribed list, with the Assessing Officer empowered to determine the price during assessment when pricing or documentation is deficient, and taxpayers must maintain prescribed documentation and furnish an accountant's report by the specified date.
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 price: related party transactions must be priced and documented to reflect independent market terms.
Income, expenses and apportioned costs from transactions between associated enterprises must be computed with regard to the arm's length price. Associated enterprises and international transactions are defined by participation in management, control or capital and by specified deeming tests. Arm's length price is determined by the most appropriate method from a prescribed list, with the Assessing Officer empowered to determine the price during assessment when pricing or documentation is deficient, and taxpayers must maintain prescribed documentation and furnish an accountant's report by the specified date.
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