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 ... order of the Transfer Pricing Officer. (7) The Transfer Pricing Officer may, for the purposes of determining the arm's length price under this section
Income Tax Act, 1961
92C. Computation of arm's length price.
(1) The arm's length price in relation to an international transaction shall ... arm's length price shall be taken to be the arithmetical mean of such prices: Provided further that if the variation between the arm's
Computation of income from international transaction having regard to arm's length price. [ Substituted by Act 14 of 2001, Section ... international transaction shall be computed having regard to the arm's length price. Explanation. - For the removal of doubts, it is hereby clarified that
income represented by any addition made in conformity with the arm's length price determined by the Transfer Pricing Officer, where the assessee had maintained
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
s length price. There are
different methods for determining appropriate transfer pricing.
Under Section 92C(1) of the I.T. Act, arm's length ... s
length price shall be taken to be the arithmetical mean
of such prices, or, at the option of the assessee, a price
which
into an advance pricing agreement with any person, determining the arm's length price or specifying the manner in which arm's length price ... into by that person. (2) The manner of determination of arm's length price referred to in sub-section (1), may include the methods referred
accrued had arm's length conditions prevailed is
brought to tax. Misreporting, if any, on account of non-arm's
ITA 102/2015 ... arm's length price :
Provided also that where more than one price is determined by
the most appropriate method, the arm's length
Enterprise was arm's
length rate of interest and the adjustment made in the
Assessment Order determining the arms' length rate of
interest ... arms length interest
rate.
14. We note that CUP method is the most
appropriate method in order to ascertain arms length
price of the international
Arm's length price". Adjustments are made in the controlled price by determining Arm's length price through different methods. This exercise ... Transfer Pricing Officer.
(7) The Transfer Pricing Officer may, for the purposes of determining the arm's length price under this section, exercise
