length price as so determined by the Transfer Pricing Officer. (5) With a view to rectifying any mistake apparent from the record, the Transfer Pricing ... 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
length price, in the manner as may be prescribed: [Provided that where more than one price is determined by the most appropriate method, the arm ... length price shall be taken to be the arithmetical mean of such prices: Provided further that if the variation between the arm's length price
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
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
length price. There are
different methods for determining appropriate transfer pricing.
Under Section 92C(1) of the I.T. Act, arm's length price ... length price shall be taken to be the arithmetical mean
of such prices, or, at the option of the assessee, a price
which may vary
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
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
attached with the return. However, the issue of determination of 'Arms Length price' was not referred to the Transfer Pricing Officer as required ... Length Price. It is therefore mandatory that in case of every international transaction, the price charged as per books must be shown to be Arm
arm's length principle.
23. Section 92C (1) of the Act prescribes the procedure to calculate
the arm's length price ... arm's length price.
38. In the case on hand, the Transfer Pricing Officer has
determined the arm's length price
result of the scrutiny proceedings before
the Transfer Pricing Officer, arm's length price adjustments were recommended in
respect of (i) interest on loans ... arm's length interest on the said transaction. As regards the claim of
the assessee that no arm's length price