Arm's length price determination under transfer pricing rules governs method selection, assessment adjustments, and related enterprise income computation. Arm's length price for an international transaction or specified domestic transaction is determined by the most appropriate method, including comparable uncontrolled price, resale price, cost plus, profit split, transactional net margin, or any other prescribed method. The Assessing Officer may determine that price during assessment where the statutory method has not been followed, required records are missing, data is unreliable, or requisitioned information is not furnished in time, after issuing a show-cause notice. Income is then computed by reference to the determined arm's length price, with no deduction under Chapter VIII for the enhanced income.
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 determination under transfer pricing rules governs method selection, assessment adjustments, and related enterprise income computation.
Arm's length price for an international transaction or specified domestic transaction is determined by the most appropriate method, including comparable uncontrolled price, resale price, cost plus, profit split, transactional net margin, or any other prescribed method. The Assessing Officer may determine that price during assessment where the statutory method has not been followed, required records are missing, data is unreliable, or requisitioned information is not furnished in time, after issuing a show-cause notice. Income is then computed by reference to the determined arm's length price, with no deduction under Chapter VIII for the enhanced income.
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