Arms length price: taxpayer pricing within a narrow margin accepted; limited assessing officer recourse and temporary document relief. Sections 92 and 92A-92F require income from international transactions between associated enterprises to be computed with reference to the arms length price, with methods and selection criteria in section 92C and rules 10A-10E; primary responsibility rests with the assessee while the Assessing Officer may determine the price under specified conditions. The Board directed that taxpayer prices within a narrow margin may be accepted, early failures to maintain prescribed documents should not trigger invocation of section 92C(3) or penalties for the initial period, and Assessing Officers may invoke section 92C(3) only where the subsection's circumstances and material information exist.
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.
Arms length price: taxpayer pricing within a narrow margin accepted; limited assessing officer recourse and temporary document relief.
Sections 92 and 92A-92F require income from international transactions between associated enterprises to be computed with reference to the arms length price, with methods and selection criteria in section 92C and rules 10A-10E; primary responsibility rests with the assessee while the Assessing Officer may determine the price under specified conditions. The Board directed that taxpayer prices within a narrow margin may be accepted, early failures to maintain prescribed documents should not trigger invocation of section 92C(3) or penalties for the initial period, and Assessing Officers may invoke section 92C(3) only where the subsection's circumstances and material information exist.
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