Computation of arm’s length price - Section 92C

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..... other words, it is the price that would have prevailed if the enterprises were at arm s length from each other i.e. where the enterprises involved were not controlled, influenced by or associated with another enterprises. It is the price that would have existed between enterprises, not associated or related with each other. Uncontrolled Conditions : Conditions which are not controlled or supp .....

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..... class of transaction or class of associated persons or functions performed by such persons. Where an assessee has entered into various types of international transactions with associated enterprises, arm s length price should be determined on a transaction-by-transaction basis and not on an aggregate basis- Development consultants (P) Ltd. v. CIT 2008 (4) TMI 340 - ITAT CALCUTTA-A Method .....

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..... not exceed such percentage not exceeding 3% of the latter (i.e. price at which international transaction has been actually undertaken) as may be notified by the Central Government in the Official Gazette in this behalf, then the price at which international transaction has actually been undertaken shall be deemed to be the arm s length price and no adjustment is required to be made. If the ar .....

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..... be the arm s length price for assessment year 2023-2024. [ Notification No. 46/2023 Dated 26th June 2023 ] Determination Arm s length price by Assessing officer: When the AO, on the basis of information or document in his possession is of the opinion that : Price has not been determined in accordance with section 92 or Data used for computing arms length price is not reliab .....

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..... pter of TDS i.e., other party cannot claim the refund of TDS. Range Concept : where in case of data set has more than 5 value then in such a case for the determination of Arm Length Price assessee shall follow Rule 10CA . - Manuals - Ready reckoner - Law and practice - Reference Guide - Quick Commentary Tax Management India - taxmanagementindia - taxmanagement - taxmanagementindia .....

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