Rule – 10, Determination of income in the case of non-residents
March 14, 2018
Rule – 10AB, Other method of determination of arm’s length price
March 14, 2018

Rule – 10A, Meaning of expressions used in computation of arm’s length price

10A. For the purposes of this rule and rules 54a[10AB] to 10E,—

54b[(a) “associated enterprise” shall,—

(i) have the same meaning as assigned to it in section 92A; and
(ii) in relation to a specified domestic transaction entered into by an assessee, include —

(A) the persons referred to in clause (b) of sub-section (2) of section 40A in respect of a transaction referred to in clause (a) of sub-section (2) of the said section;
(B) other units or undertakings or businesses of such assessee in respect of a transaction referred to in section 80A or, as the case may be, sub-section (8) of section 80-IA;
(C) any other person referred to in sub-section (10) of section 80-IA in respect of a transaction referred to therein;
(D) other units, undertakings, enterprises or business of such assessee, or other person referred to in sub-section (10) of section 80-IA, as the case may be, in respect of a transaction referred to in section 10AA or the transactions referred to in Chapter VI-A to which the provisions of sub-section (8) or, as the case may be, the provisions of sub-section (10) of section 80-IA are applicable;

(aa) “enterprise” shall have the same meaning as assigned to it in clause (iii) of section 92F and shall, for the purposes of a specified domestic transaction, include a unit, or an enterprise, or an undertaking or a business of a person who undertakes such transaction;]

54c[(ab)] “uncontrolled transaction” means a transaction between enterprises other than associated enterprises, whether resident or non-resident;

(b) “property” includes goods, articles or things, and intangible property;
(c) “services” include financial services;
(d) “transaction” includes a number of closely linked transactions.

Reference: www.incometaxindia.gov.in

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