Rule-10A (of Income Tax Rules, 1962), Meaning of expressions used in computation of arm's length price

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 (of Income Tax Act, 1961); 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 (of Income Tax Act, 1961) 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 (of Income Tax Act, 1961) or, as the case may be, sub-section (8) of section 80-IA (of Income Tax Act, 1961);

(C) any other person referred to in sub-section (10) of section 80-IA (of Income Tax Act, 1961) 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 (of Income Tax Act, 1961), as the case may be, in respect of a transaction referred to in section 10AA (of Income Tax Act, 1961) 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 (of Income Tax Act, 1961) are applicable;

(aa) "enterprise" shall have the same meaning as assigned to it in clause (iii) of section 92F (of Income Tax Act, 1961) 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.