Arm's length price governs inter-enterprise transactions to determine tax adjustments under transfer pricing rules and related sections. Definitions set the standard for determining arm's length price-the price between independent parties in uncontrolled conditions-for application to transfer pricing and anti-avoidance provisions. Enterprise encompasses persons or permanent establishments engaged in production, IP exploitation, services, contract work, investment or securities dealings, including activities through units or subsidiaries. 'Permanent establishment' includes a fixed place of business; 'specified date' is one month before the income tax return due date; and 'transaction' covers arrangements or concerted actions whether formal, written or enforceable.
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 governs inter-enterprise transactions to determine tax adjustments under transfer pricing rules and related sections.
Definitions set the standard for determining arm's length price-the price between independent parties in uncontrolled conditions-for application to transfer pricing and anti-avoidance provisions. Enterprise encompasses persons or permanent establishments engaged in production, IP exploitation, services, contract work, investment or securities dealings, including activities through units or subsidiaries. "Permanent establishment" includes a fixed place of business; "specified date" is one month before the income tax return due date; and "transaction" covers arrangements or concerted actions whether formal, written or enforceable.
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