COMPUTATION OF INCOME HAVING REGARD TO THE ALP – SECTION 92 – APPLICABILITY OF ARM’S LENGTH PRINCIPLE

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• Any income arising from international transaction shall be computed on the basis of arm’s length price.

  • Exports to its non-resident AE L Ltd.
  • Service provided to AE L Ltd.

• Any expense/ allowance for any interest, for computing income for international transaction shall also be computed on the basis of arm’s length price of such expense/interest.

  • Service received from AE N Ltd.
  • Import from its non-resident AE N Ltd.

• The cost or expenses allocated or apportioned between Associated enterprises under a mutual agreement or arrangement shall be at arm’s length price.

• Any contribution to any cost, expenses, for obtaining any benefit/service/facility to AE shall also be computed on the basis of the ALP of such benefit/service/facility

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