Arm's length price documentation rules require detailed records, comparables, pricing methods, and contemporaneous support for related transactions. Rule 84 requires persons entering into international transactions or specified domestic transactions to maintain detailed documentation for arm's length price determination, including ownership structure, group profile, business and transaction details, functions-risks-assets analysis, comparable uncontrolled transactions, pricing methods, working papers, assumptions, and transfer price adjustments. The rule recognises exceptions and modified documentation for specified thresholds and for eligible specified domestic transactions, permits reliance on authentic supporting documents such as publications, accounts, contracts and correspondence, requires contemporaneous records as far as possible, and mandates retention for the prescribed period.
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Provisions expressly mentioned in the judgment/order text.
Arm's length price documentation rules require detailed records, comparables, pricing methods, and contemporaneous support for related transactions.
Rule 84 requires persons entering into international transactions or specified domestic transactions to maintain detailed documentation for arm's length price determination, including ownership structure, group profile, business and transaction details, functions-risks-assets analysis, comparable uncontrolled transactions, pricing methods, working papers, assumptions, and transfer price adjustments. The rule recognises exceptions and modified documentation for specified thresholds and for eligible specified domestic transactions, permits reliance on authentic supporting documents such as publications, accounts, contracts and correspondence, requires contemporaneous records as far as possible, and mandates retention for the prescribed period.
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