Rule 78

Other method for determination of arm‘s length price

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For the purposes of section 165(1)(f), the other method for determination of the arm's length price in relation to an international transaction or a specified domestic transaction shall be any method which takes into account the price, which —

(a) has been charged or paid; or

(b) would have been charged or paid,

for the same or similar uncontrolled transaction, with or between non-associated enterprises, under similar circumstances, considering all the relevant facts.

← PreviousRule 77 – Meaning of expressions used in determination of arm‘s length price Next →Rule 79 – Determination of arm‘s length price under section 165

Source: Income-tax Rules, 2026, notified by the CBDT vide G.S.R. 198(E) dated 20 March 2026. For reference only – please verify with the official Gazette.