Meaning of expressions used in computation of arm’s length price.
Rule 10A
For the purposes of this rule and rules 10AB to 10E,— (a) “associated enterprise” shall,—
(i) have the same meaning as assigned to it in section 92A; and
(ii) in relation to a specified domestic transaction entered into by an assessee, include —
(A) the persons referred to in clause (b) of sub-section (2) of section 40A in respect of a transaction referred to in clause (a) of sub-section (2) of the said section.
(B) other units or undertakings or businesses of such assessee in respect of a transaction referred to in section 80A or, as the case may be, sub-section (8) of section 80-IA.
(C) any other person referred to in sub-section (10) of section 80-IA in respect of a transaction referred to therein;
(D) other units, undertakings, enterprises or business of such assessee, or other person referred to in sub-section (10) of section 80-IA, as the case may be, in respect of a transaction referred to in section 10AA or the transactions referred to in Chapter VI-A to which the provisions of sub-section (8) or, as the case may be, the provisions of sub-section (10) of section 80-IA are applicable.
(aa) “enterprise” shall have the same meaning as assigned to it in clause (iii) of section 92F 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.
(ab) “uncontrolled transaction” means a transaction between enterprises other than associated enterprises, whether resident or non-resident;
(b) “property” includes goods, articles or things, and intangible property;
(c) “services” include financial services;
(d) “transaction” includes a number of closely linked transactions.