TMI BlogComputation of arms length priceX X X X Extracts X X X X X X X X Extracts X X X X ..... ( e ) transactional net margin method; ( f ) such other method as may be prescribed by the 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 as may be prescribed : 1 [Provided that where more than one price is determined by the most appropriate method, the 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 length price so determined and price at which the 7 [ international transaction or specified domestic transaction ] has actually been undertaken 5 [ does not exceed such percentage not exceeding three per cent of the latter, as may ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion (2A) shall empower the Assessing Officer either to assess or reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154 for any assessment year the proceedings of which have been completed before the 1st day of October, 2009. ] (3) Where during the course of any proceeding for the assessment of income, the Assessing Officer is, on the basis of material or information or document in his possession, of the opinion that- ( a ) the price charged or paid in an 7 [ international transaction or specified domestic transaction ] has not been determined in accordance with sub-sections (1) and (2); or ( b ) any informat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... AA ] or section 10B or under Chapter VI-A shall be allowed in respect of the amount of income by which the total income of the assessee is enhanced after computation of income under this sub-section : Provided further that where the total income of an associated enterprise is computed under this sub-section on determination of the arm's length price paid to another associated enterprise from which tax has been deducted 3 [ or was deductible ] under the provisions of Chapter XVIIB, the income of the other associated enterprise shall not be recomputed by reason of such determination of arm's length price in the case of the first mentioned enterprise. ------------------------------- Notes :- 1. S ..... X X X X Extracts X X X X X X X X Extracts X X X X
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