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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 between persons other than associated enterprises, in uncontrolled conditions. In 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, in .....

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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) The arm s length price in relation to an international transaction or specified domestic transaction shall be determined by any of the method specified in this section, being the most appropriate method, having regard to the nature of transaction o .....

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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 sub section (1) shall be applied, for determination of arm length price in the manner as we prescribed. 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 arithmeti .....

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