Report from an accountant to be furnished by persons entering into international transaction or specified domestic transaction Every person who has entered into an international transaction or specified domestic transaction during a previous year shall obtain a report from an accountant and furnish such report on or before the specified date in the prescribed form […]

Maintenance, keeping and furnishing of information and document by certain persons (1) Every person,— (i) who has entered into an international transaction or specified domestic transaction shall keep and maintain such information and document in respect thereof as may be prescribed43; (ii) being a constituent entity of an international group, shall keep and maintain such

Secondary adjustment in certain cases (1) Where a primary adjustment to transfer price,—  (i) has been made suo motu by the assessee in his return of income; (ii) made by the Assessing Officer has been accepted by the assessee; (iii) is determined by an advance pricing agreement entered into by the assessee under section 92CC, on or after

Effect to advance pricing agreement  (1) Notwithstanding anything to the contrary contained in section 139, where any person has entered into an agreement and prior to the date of entering into the agreement, any return of income has been furnished under the provisions of section 139 for any assessment year relevant to a previous year to which such

Advance pricing agreement (1) The Board, with the approval of the Central Government, may enter into an advance pricing agreement with any person, determining the— (a) arm’s length price or specifying the manner in which the arm’s length price is to be determined, in relation to an international transaction to be entered into by that

Power of Board to make safe harbour rules (1) The determination of— (a) income referred to in clause (i) of sub-section (1) of section 9; or (b) arm’s length price under section 92C or section 92CA, shall be subject to safe harbour rules40. (2) The Board may, for the purposes of sub-section (1), make rules for safe harbour. Explanation.—For the purposes

📌 Transfer pricing regulations in India ensure that international and specified domestic transactions between associated enterprises adhere to the arm’s length principle (ALP). A key provision governing transfer pricing is Section 92CA, which outlines the powers and functions of the Transfer Pricing Officer (TPO) in determining ALP. 🔹 Reference to the Transfer Pricing Officer Under

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 following methods, being the most appropriate method, having regard to the nature of transaction or class of transaction or class of associated persons or functions performed by such

Meaning of specified domestic transaction For the purposes of this section and sections 92, 92C, 92D and 92E, “specified domestic transaction” in case of an assessee means any of the following transactions, not being an international transaction, namely:—  (i) [***] (ii) any transaction referred to in section 80A; (iii) any transfer of goods or services referred to in sub-section (8) of section

Meaning of international transaction (1) For the purposes of this section and sections 92, 92C, 92D and 92E, “international transaction” means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any