Section 159 of Income Tax Act, 2025 : Agreement with foreign countries or specified territories and adoption by Central Government of agreement between specified associations for double taxation relief.

(1) The Central Government may enter into an agreement with the Government of—(a) any other country;or(b) any specified territory, for the purposes mentioned in sub-section (3), and may, by notification, make such provisions as necessary for implementing the agreement.(2) Any specified association in India may enter into an agreement with any specified association in the

Section 161 of Income Tax Act, 2025 : Computation of income from international transaction and specified domestic transaction having regard to arm’s length price.

(1) Any income arising from an international transaction or a specified domestic transaction shall be determined having regard to the arm’s length price.(2) Any allowance for any expense or interest arising from an international transaction or a specified domestic transaction shall also be determined having regard to the arm’s length price.(3) If in an international

Section 162 of Income Tax Act, 2025 : Meaning of associated enterprise.

(1) In this Chapter, “associated enterprise”, in relation to another enterprise, means an enterprise—(a) which participates, directly or indirectly, or through one or more intermediaries, in the management or control or capital of the otherenterprise; or(b) in respect of which one or more persons who participate, directly or indirectly, or through one or more intermediaries,

Section 163 of Income Tax Act, 2025 : Meaning of international transaction.

(1) In this Chapter, “international transaction” means a transaction between two or more associated enterprises, one of which is necessarily a non-resident, and includes—(a) the purchase, sale, transfer, lease or use of tangible property, including building, transportation vehicle, machinery, equipment, tools, plant, furniture, commodity or any other article, product or thing;(b) the purchase, sale, transfer,

Section 164 of Income Tax Act, 2025 : Meaning of specified domestic transaction.

In this Chapter, “specified domestic transaction” in case of an assessee means any of the following transactions, not being an international transaction—(a) any transaction referred to in section 122;(b) any transfer of goods or services referred to in section 140(9);(c) any business transacted between the assessee and other person as referred to in section 140(13);(d)

Section 165 of Income Tax Act, 2025 : BDetermination 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 following methods, being the most appropriate method––(a) comparable uncontrolled price method;(b) resale price method;(c) cost plus method;(d) profit split method;(e) transactional net margin method;(f) such other method as prescribed by the Board.(2) The