Rule 81 prescribes dataset construction, weighted averages, and a 35th–65th percentile arm’s length range when multiple comparable prices arise, with the median applied if the transaction falls outside the range.
Draft Rule 80 prescribes criteria for selecting the most appropriate transfer pricing method based on transaction nature, comparability, data reliability, and functional analysis.
Draft Rule 79 sets out recognized methods and comparability criteria for determining arm’s length price under section 165, mandating use of the most appropriate method and current-year data for accurate benchmarking.
Draft Rules 77 and 78 clarify essential transfer pricing definitions and allow an alternative comparability-based method for determining arms length price. The provisions expand scope while enabling practical pricing based on similar uncontrolled transactions.
Draft Rules 75 and 76 prescribe mandatory forms, timelines, and verification requirements for claiming treaty relief and foreign tax credit, limiting credit to actual tax liability and disallowing unsupported or disputed claims.
Draft Rule 74 permits specified persons to defer taxation of income accrued in foreign retirement benefit accounts until withdrawal in a notified country. The option, once exercised in Form 40, is binding and subject to reversal if residential status changes.
Draft Rule 73 prescribes structured formulas for computing relief under Section 157(1) where tax liability increases due to arrears, gratuity, compensation or pension commutation. It standardizes multi-year tax averaging and mandates filing Form 39 to claim the benefit.
Draft Rules 67 to 72 prescribe specific forms and designated authority certifications for claiming deductions under Sections 144 to 152. The rules standardize reporting, audit documentation, and regulatory verification as a precondition for availing tax benefits.
Examines whether Tax Deducted at Source, while legally valid, creates working capital strain by forcing early tax payment before profits are determined.
Section 60 of the CGST Act allows temporary tax payment when liability is uncertain, ensuring business continuity while protecting revenue.
