Income Tax Department

Ministry of Finance, Government of India

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Rule Number 77

Meaning of expressions used in determination of arm’s length price

Rule Number

77

Upload Date

08/01/2026

Meaning of expressions used in determination of arm's length price.

77. For the purpose of this rule and rules 78 to 84,—

(a)  "associated enterprise" shall have the meaning assigned to it in section 162;
(b)  "enterprise" shall have the meaning assigned to it in section 173(b) and shall, for the purposes of a specified domestic transaction, include a unit, or an enterprise, or an undertaking or a business of a person who undertakes such transaction;
(c)  "property" includes goods, articles or things and intangible property;
(d)  "services" include financial services;
(e)  "transaction" includes a number of closely linked transactions; and
(f)  "uncontrolled transaction" means a transaction between enterprises other than associated enterprises, whether resident or non-resident.

Footnotes