(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, […]

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)

(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

1) Where,—(a) the assessee has entered into an international transaction or specified domestic transaction in any tax year; and(b) the Assessing Officer considers it necessary or expedient so to do, he may refer the determination of the arm’s length price in relation to such transaction to the Transfer Pricing Officer, with the previous approval of

(1) The determination of—(a) income referred to in section 9(2); or(b) arm’s length price under section 165 or 166, shall be subject to safe harbour rules.(2) For the purposes of sub-section (1), the Board may make rules for safe harbour.(3) In this section, “safe harbour” means circumstances in which the incometax authorities shall accept,–– (a) the

(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 person;(b) income referred to

(1) If a return of income for any tax year covered by an advance pricing agreement has been furnished by any person, before the date of entering into the said agreement, he shall, irrespective of anything to the contrary contained in section 263, furnish a modified return, in accordance with and limited to the agreement,

(1) An assessee shall make a secondary adjustment in every case where primary adjustment of one crore rupees or more to transfer price—(a) has been made on his own in his return of income;(b) made by the Assessing Officer has been accepted by him;(c) is determined by an advance pricing agreement entered into by him

(1) Every person,––(a) who has entered into an international transaction or specified domestic transaction; or(b) is a constituent entity of an international group, shall keep and maintain such information and document in respect thereof and forsuch period and in such manner, as prescribed.(2) The Assessing Officer or the Commissioner (Appeals) may, during any proceeding under

Every person who has entered into an international transaction or specified domestic transaction during a tax year shall obtain a report from an accountant and furnish such report on or before the specified date in the prescribed form duly signed and verified in the manner as prescribed by such accountant and setting forth such particulars