Rules, 1962
10A. Meaning of expressions used in computation of arm's length price.
- For the purposes of this rule and rules 10AB
specified domestic transaction; (f) any other method as provided in rule 10AB. (2) For the purposes of sub-rule (1), the comparability of an international
Section 10AB in Income Tax Rules, 1962
10AB. Other method of determination of arm's length price.
- For the purposes of clause
method) as referred to in Rule 10B(1)(f) of the Rules
[any other method] as provided under Rule 10AB of the Rules would ... Rule 10B(1) of the Rules also includes
'any other method' as may be provided under Rule 10AB of the Rules. Rule
10AB
assessee has selected 'other
method' as per Rule 10AB of the Income Tax Rules, 1962 and has claimed
that its transactions with ... assessee by adopting 'other method' as per
Rule 10AB of the Income Tax Rules, 1962, in light relevant information,
including agreement between
done any comparability analysis other than quoting other
method as per Rule 10AB. The learned TPO did not conduct any
comparability analysis to determine ... failure to apply any prescribed method under Rule 10B or justify
invocation of Rule 10AB with suitable benchmarks results in a fundamental
breach
based upon any of the prescribed methods under Rule 10B or
Rule 10AB, nor did it contain any quantitative analysis,
filters, or empirical data ... attributing margins to
assorted functional clusters was contrary to Rule 10B, Rule
10AB, and every canon of transfer-pricing analysis. No
comparable data, quantitative filters
Rules. The Ld. DR demonstrated
the receipt of services by the assessee before us too. It is further observed
that while applying Rule 10AB ... Rules, is not sufficient for a valid transfer pricing adjustment. The Ld.
CIT(A) has correctly concluded that, in accordance with Rule 10AB,
the assessee
aggregation. He took recourse to ‗any other method' under
rule 10AB of the Income-tax Rules, 1962 (hereinafter referred
4
ITA No.2986 ... have not totally ruled out
the application of the CUP under rule 10B(1)(a) or other
method under rule 10AB or the TNMM under
Other Method" as per the
requirement of Rule 10AB of the Income Tax Rules, 1962 ("the Rules ... Rules,
is not sufficient for a valid transfer pricing adjustment. The Ld. CIT(A) has
correctly concluded that, in accordance with Rule 10AB, the assessee