ramesh (n/a) 01 June 2010
Hi
The Provisio of Section 92 C (2) defines
"....that where more than one price is determined by the most appropriate method, the arm's length price shall be taken to be the arithmetical mean of such price.................."
in the above what does it means by more than one price ?
Please advice
Many thanks
Regards
Ramesh
Vineet (Director) 01 June 2010
Dear Mr Ramesh
As per provisions of section 92C(1), the ALP is to be determined appying the most appropriate method as per prescribed guidelines. The proviso to section 92C(2), talks about multiple ALP applying the most approriate method which can result only due to multiplicity of comparable instances such as companies, transations, margins etc. However in computing all these prices the most appropriate method remains identical.
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