Computation of income from international transaction having regard to arms length price
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.... international transaction shall be computed having regard to the arm's length price. Explanation.-For the removal of doubts, it is hereby clarified that the allowance for any expense or interest arising from an international transaction shall also be determined having regard to the arm's length price. (2) Where in an 3[international transaction or specified domestic transaction], two or....
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....ly in a case where the computation of income under 5[sub-section (1) or sub-section (2A)] or the determination of the allowance for any expense or interest under 6[sub-section (1) or sub-section (2A)], or the determination of any cost or expense allocated or apportioned, or, as the case may be, contributed under sub-section (2), 4[or sub-section (2A)] has the effect of reducing the income chargeab....
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....expected to arise in that business, the Assessing Officer shall determine the amount of profits which may reasonably be deemed to have been derived therefrom and include such amount in the total income of the resident." 2. Substituted vide Section 39 of the Finance Act, 2002 w.e.f. 01-04-2002 before it was read as, "92. Computation of income from international transaction having regard to....




TaxTMI
TaxTMI