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This book provides a comprehensive commentary on the law relating to Transfer Pricing. The Present Publication is the 9th Edition, which incorporates all the changes made by the Finance (No. 2) Act, 2019. The key features of this book are as follows: (1) Detailed discussion on Transfer Pricing provisions and associated rules (2) Clause-wise discussion on Transfer Pricing Audit report (3) Analysis of various landmark rulings (4) Covering all department communications on TP provisions (5) Comparison of various provisions in Tabular format (6) Discussion on all compliances related to Transfer Pricing (7) This book is divided into five divisions, namely: (a) General Principles of Transfer Pricing (i) Introduction (ii) Features of the Transfer Pricing Regime under Chapter X (iii) Transfer Pricing Provisions of Chapter X – When Applicable to an Assessee (iv) Transfer Pricing Compliances (b) Applicability of Transfer Pricing Provisions to International Transactions (i) Who are Associated Enterprises? (ii) What is International Transaction? (iii) International Transaction: Purchase, Sale or Lease of Tangible Property (iv) International Transaction: Intangible Property Transactions (v) International Transaction: Borrowing or Lending of Money/Financing (vi) International Transaction: Provision of Services (vii) International Transaction: Cost Contribution Agreements (viii) Business Restructuring or Organisation (c) Computation of Arm’s Length Price of International Transactions (i) What is Arm’s Length Price (ii) How to Compute Arm’s Length Price (d) Comparability Analysis of International Transactions (i) Benchmarking: Comparability Analysis & Comparables (ii) Understanding Business, Industry and Controlled Transactions (iii) Examination of Comparability Factors of Controlled Transactions (iv) Tested Party (v) Identification of Comparables (vi) Data to be used in Comparability Analysis (vii) What is Comparable Uncontrollable Price (CUP) Method and How to Apply it to Calculate ALP? (viii) What is Resale Price Method (RPM) and How to Apply it to Calculate ALP? (ix) What is Cost Plus Method (CPM) and How to Apply it to Calculate ALP? (x) What is Profit Split Method (PSM) and How to Apply it to Calculate ALP? (xi) What is Transactional Net Margin Method (TNMM) and How to Apply it to Calculate ALP? (xii) Any Other Method – Rule 10AB (xiii) Most Appropriate Method (MAM) (xiv) International Transactions: Determination of ALP for Import of Goods (xv) International Transactions: Determination of ALP for Interest Free Loan to AEs (xvi) International Transactions Involving Intangibles: Determination of ALP (xvii) International Transactions: When Development Centres in India can be Treated as Contract R&D Service Provider with Insignificant Risk (xviii) International Transactions: Determination of ALP for Indenting Activity (e) TP Adjustments, Thin Capitalisation Adjustments & Secondary Adjustments in International Transactions (i) Transfer Pricing Adjustments (ii) Thin Capitalisation Adjustments (iii) Secondary Adjustments (f) Transfer Pricing Procedures (i) Power of AO to Compute ALP (ii) Reference to Transfer Pricing Officer -Section 92CA (iii) Transfer Pricing Dispute Resolution Mechanism (iv) Safe Harbour Rules (v) Advance Pricing Agreement (vi) Obligation of Assessee to Maintain Transfer Pricing Documentation (vii) Audit Report (viii) Audit Report & Documentation – International Transactions (ix) Due Date for Filing Return for Assessee Required to Furnish Audit Report u/s 92E – Section 139 (x) Time Limit for Assessment and Reassessment – Sections 153 and 153B (g) Specified Domestic Transaction (i) Definition of Specified Domestic Transactions (ii) Audit Report & Documentation – Specified Domestic Transactions (h) Miscellaneous (i) Penalty – Sections 271, 271AA, 271BA and 271G