SUBSCRIBE(free)-Daily Updates (Click Verification Link Received in Your Email)

Rule 10C of Income Tax Rules 1962: Most appropriate method (arm's length price)

Rule 10C - Most appropriate method (arm's length price)

(1) For the purposes of sub-section (1) of section 92C, the most appropriate method shall be the method which is best suited to the facts and circumstances of each particular international transaction or specified domestic transaction, and which provides the most reliable measure of an arm's length price in relation to the international transaction or the specified domestic transaction, as the case may be.

(2) In selecting the most appropriate method as specified in sub-rule (1), the following factors shall be taken into account, namely:—
(a) the nature and class of the international transaction or the specified domestic transaction;
(b) the class or classes of associated enterprises entering into the transaction and the functions performed by them taking into account assets employed or to be employed and risks assumed by such enterprises;
(c) the availability, coverage and reliability of data necessary for application of the method;
(d) the degree of comparability existing between the international transaction or the specified domestic transaction and the uncontrolled transaction and between the enterprises entering into such transactions;
(e) the extent to which reliable and accurate adjustments can be made to account for differences, if any, between the international transaction or the specified domestic transaction and the comparable uncontrolled transaction or between the enterprises entering into such transactions;
(f) the nature, extent and reliability of assumptions required to be made in application of a method.


Extra Notes for Readers:

- Rule 10C was introduced by the Income Tax (Twenty First Amendment) Rules, 2001, w.e.f. 21-8-2001



Reference/Source: Check at Income Tax site for latest version of the Rules - link

This page was last updated on 17th October 2016.
Submit/See Comments With: or

No comments:

Post a Comment