Transfer pricing agreement terms govern critical assumptions, binding effect, notice requirements, and revision or cancellation procedures. Agreement terms under the Income-tax Rules may cover international transactions, transfer pricing methodology, determination of arm's length price, definitions of relevant terms, critical assumptions, rollback provisions, and other agreed conditions. The agreement ceases to be binding if a critical assumption changes or conditions are not met, and may then be revised or cancelled. Written notice of such change or failure must be given by the assessee to the Principal Chief Commissioner and by the Board to the assessee, with revision and cancellation governed by the prescribed rules.
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.
Transfer pricing agreement terms govern critical assumptions, binding effect, notice requirements, and revision or cancellation procedures.
Agreement terms under the Income-tax Rules may cover international transactions, transfer pricing methodology, determination of arm's length price, definitions of relevant terms, critical assumptions, rollback provisions, and other agreed conditions. The agreement ceases to be binding if a critical assumption changes or conditions are not met, and may then be revised or cancelled. Written notice of such change or failure must be given by the assessee to the Principal Chief Commissioner and by the Board to the assessee, with revision and cancellation governed by the prescribed rules.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.