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Section 92C - Computation of arm’s length price

Income Tax - Transfer Pricing - International + Domestic - 06 - Section 92C - Meaning and Computation of arm s length price Meaning of Arm s length price: Arm s length price means a price which is applied or proposed to be applied in a transaction be .....

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fluenced 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 suppressed or moulded for achi .....

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constitute arm s length price: The price should be applied or proposed to be applied in a transaction; The transaction is between unrelated persons; and The transaction is taking place in uncontrolled conditions. Computation of Arm s length price (1 .....

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r 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 tra .....

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uncontrolled price method; (CUPM) Resale price method; (RPM) Cost plus method; (CPM) Profit split method; (PSM) Transactional net margin method; (TNMM) Such other method as may be prescribed by the Board. (2) The most appropriate method refer to in s .....

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cal mean of such prices Provided further, if the variation between: (a) the arm s length price so determined , and (b) price at which international transaction has been actually undertaken, does not exceed such percentage not exceeding 3% of the latt .....

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be deemed to be the arm s length price and no adjustment is required to be made. If the arithmetic means is not within the percentage as may be notified (maximum however is 3%) of price at which the international transaction has actually been underta .....

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h price in relation to an international transaction undertaken on or after the 1st day of April, 2014, shall be computed in such manner as may be prescribed and accordingly the first and second proviso shall not apply. (3) Determination Arm s length .....

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