https://www.taxtmi.com/caselaws?id=270845 Determination of arm's length price requires assessment of each international transaction separately when transactions are not closely linked; consequently, an assessing officer may adjust declared ALP if price variation exceeds the accepted threshold, with such adjustment upheld where variation is more than five percent. The proviso providing that ALP may be the arithmetic mean of multiple prices applies only where more than one price is determined under the most appropriate method; where only a single price is determined under the method, that proviso is inapplicable and no concession under it arises. en-us Wed, 28 Oct 2015 00:00:00 +0530 Sat, 24 Jan 2026 11:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=270845 Determination of arm's length price requires assessment of each international transaction separately when transactions are not closely linked; consequently, an assessing officer may adjust declared ALP if price variation exceeds the accepted threshold, with such adjustment upheld where variation is more than five percent. The proviso providing that ALP may be the arithmetic mean of multiple prices applies only where more than one price is determined under the most appropriate method; where only a single price is determined under the method, that proviso is inapplicable and no concession under it arises. Case-Laws Income Tax Wed, 28 Oct 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=270845