As per Rule 10 C of the Indian Income Tax Rules 1962, what factors shall be taken into account while selecting the most appropriate Transfer Pricing Method?
CS Professional · Advanced Direct Tax Laws and Practice · PYQS · June 2026
As per Rule 10 C of the Indian Income Tax Rules 1962, what factors shall be taken into account while selecting the most appropriate Transfer Pricing Method?
Answer & Explanation:
Rule 10C of the Income Tax Rules, 1962 states that in selecting a most appropriate method of Transfer Pricing, the following factors shall be taken into account namely, The nature and class of the international transaction or specified domestic transaction. 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. The availability, coverage and reliability of data necessary for application of the method. The degree of comparability existing between the international transaction or specified domestic transaction and the uncontrolled transaction and between the enterprises entering into such transactions. The extent to which reliable and accurate adjustments can be made to account for differences, if any, between the international transaction or specified domestic transaction and the comparable uncontrolled transactions or between the enterprises entering into such transactions. The nature, extent and reliability of assumptions required to be made in the application of a method.
Topics: Transfer Pricing
Related Questions in this Topic
- Canada Ltd., a Canadian company has a subsidiary, Maharana Ltd. in India. Canada Ltd. sells computer monitors to Maharan...
- Simi Techno Ltd. (STL) is an Indian company, having its head office in Mumbai. For the P.Y. 2024-25, it furnished the fo...
- ABC Ltd., Chennai is a part of a large multi-national group. It is engaged in the manufacturing of kids' high-quality to...
- Ashok aged 54 years, is a salaried employee with TMS Limited. He has furnished the following details for the PY 2025-26:...
- Explain in brief whether in the following independent cases, will GAAR provisions apply. (v) Foreign Portfolio Investors...