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34. Before we consider the assessee's arguments, it would be useful to refer to the main provisions in this regard. As per section 92C(1), the ALP is determined by any of the following methods, being the most appropriate method, having regard to the nature of transaction or class of transaction or class of associated persons or functions performed by such persons or such other relevant factors as the board may prescribe, namely (a) comparable uncontrolled price method, (b) resale price method, (c) cost + method, (d) profit split method, (e) transactional net margin method, (f) any such other method as may be prescribed by the board. Where more than one price is determined by the most appropriate method, the arm's length price shall be taken to be arithmetical mean of such prices. Rule 10B of the Income Tax Rules, 1962 prescribes the determination of arm's length price u/s 92C. The first and foremost step in all the methods is to evaluate the differences between the international transaction undertaken with the unrelated enterprise performing the comparable functions in similar circumstances. Rule 10B(1)(a) deals with comparable uncontrolled price method. In this method first we have to identify the price charged or paid for property transferred or services provided in a comparable uncontrolled transaction or a number of transaction and then to adjust the price to account for differences, if any, between the international transaction and the comparable uncontrolled transactions or between the enterprises entering into such transactions, which could materially affect the price in the open market. This methodogy is followed in all the methods in the manner prescribed in Rule 10B in respect of various methods.