Principal Commissioner or Commissioner, refer the computation of the arm's length price in relation to the said international transaction or specified domestic transaction under ... rely in support of the computation made by him of the arm's length price in relation to the international transaction or specified domestic transaction
Section 92C in The Income Tax Act, 1961
92C. Computation of arm's length price.
(1) The arm's length price in relation ... section (1) shall be applied, for determination of arm's length price, in the manner as may be prescribed: [Provided that where more than
Computation of income from international transaction having regard to arm's length price. [ Substituted by Act 14 of 2001, Section ... from an international transaction shall be computed having regard to the arm's length price. Explanation. - For the removal of doubts, it is hereby clarified
determined on the basis of cost to the employer under an arm's length transaction as reduced by the employee's contribution, if any : Provided
reported income represented by any addition made in conformity with the arm's length price determined by the Transfer Pricing Officer, where the assessee
Definitions of certain terms relevant to computation of arm's length price, etc.
- In sections ... Explanation below sub-section (2) of section 288; (ii) "arm's length price" means a price which is applied or proposed to be applied
year 2003-04. The TPO accepted all of them to be Arm‟s
Length Transactions, except the payment of brand fee/ royalty ... made by the assessee to its Associated
Enterprise, while determining the Arm‟s Length Price"?
ASSESSMENT YEAR 2002-03
"Whether on the facts
transfer pricing
legislation. The said Treaty either advocates application of
arm's length principle or provides a mechanism for avoiding
double taxation on income ... most appropriate method for the determination of the
Arm's Length Price (ALP) in respect of the service agreement
dated 14.4.2005 between the applicant
enter into an advance pricing agreement with any person, determining the arm's length price or specifying the manner in which arm's length price ... entered into by that person. (2) The manner of determination of arm's length price referred to in sub-section (1), may include the methods
number - selected
as comparables for the purposes of ascertaining the Arm's Length Price
(hereafter 'ALP'). According to the Assessee ... correct profits and gains,
neither under nor over stated. Arm's length price seeks to
correct distortion and shifting of profits
