TaxTMI 
TaxTMI 
Computation of arm’s length price - Section 92C
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.... the price that would have prevailed if the enterprises were at arm's length from each other i.e. where the enterprises involved were not controlled, influenced by or associated with another enterprises. It is the price that would have existed between enterprises, not associated or related with each other. Uncontrolled Conditions: Conditions which are not controlled or suppressed or moulded for a....
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....associated persons or functions performed by such persons. Where an assessee has entered into various types of international transactions with associated enterprises, arm's length price should be determined on a transaction-by-transaction basis and not on an aggregate basis- Development consultants (P) Ltd. v. CIT 2008 (4) TMI 340 - ITAT CALCUTTA-A Methods of computing arm's length price - Arm'....
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....of the latter (i.e. price at which international transaction has been actually undertaken) as may be notified by the Central Government in the Official Gazette in this behalf, then the price at which international transaction has actually been undertaken shall be deemed to be the arm's length price and no adjustment is required to be made. If the arithmetic means is not within the percentage as m....
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....fication No. 46/2023 Dated 26th June 2023 ] * assessment year 2024-2025. [ Notification No. 116/2024 Dated 18.10.2024 ] * Determination Arm's length price by Assessing officer: * When the AO, on the basis of information or document in his possession is of the opinion that : * Price has not been determined in accordance with section 92 or * Data used for computing arms length price is not....