international transaction or specified domestic transaction in accordance with sub-section (3) of section 92C and send a copy of his order to the Assessing ... section (3), the Assessing Officer shall proceed to compute the total income of the assessee under sub-section (4) of section 92C in conformity with
Section 92C in The Income Tax Act, 1961
92C. Computation of arm's length price.
(1) The arm's length price in relation ... Board. (2) The most appropriate method referred to in sub-section (1) shall be applied, for determination of arm's length price, in the manner
Meaning of associated enterprise.
Section 92A . (1) For the purposes of this section and
sections 92 , 92B , 92C , 92D , 92E and 92F , "associated
enterprise ... prescribed.
Meaning of international transaction.
Section 92B . (1) For the purposes of this section and
sections 92 , 92C , 92D and 92E , "international
transaction
Section 40 in Finance Act, 2012
40. Insertion of new sections 92CC and 92CD.
- After section 92CB of the Income-tax Act, the following sections ... price referred to in sub-section (1), may include the methods referred to in sub-section (1) of section 92C or any other method, with
price". Section 92A defines the term 'Associated Enterprises' while section 92B defines the term 'international transaction'. Section 92C provides that ... subsection (1) of Section 131 or Sub-section (6) of Section 133 .
Explanation - For the purpose of this section, "Transfer Pricing Officer " means
length price so determined. However, no
deduction under section 10A [or section 10AA ] or section 10B or
ITA 475/2012 Page 17
under Chapter ... relation to the international transaction in accordance with
sub-section (3) of section 92C and send a copy of his order to the
Assessing Officer
length price in an international
transaction is contained in sub-section (3) of section 92C .
However, section 92CA provides that where the Assessing
Officer considers ... done by the TPO under
sub-section (3) of section 92CA , read with sub-section (3)
of section 92C , the computation of total income having
clause (b) of sub-section (1), may include the methods referred to in sub-section (1) of section 92C or the methods provided by rules ... necessary or expedient so to do. (3) Notwithstanding anything contained in section 92C or section 92CA or the methods provided by rules made under this
Section 37 in Finance Act, 2012
37. Amendment of section 92C.
- In section 92C of the Income-tax Act, - (a) in sub-section
Sony Ericsson Mobile Communications ... vs Commissioner Of Income Tax ??? Iii on 16 March, 2015
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