Rule 78 - Other method for determination of arm's length price
Reviewed by CA Nikhil Gupta · Last reviewed 29 August 2026
Local extract available Legacy mapping: 10AB
Primary authority: Notification No. 22/2026 / G.S.R. 198(E)
Currentness control: Base Rules effective 1 April 2026. Check later amendments, corrigenda and portal implementation before action.
Rule text held in the production corpus
Local extract SHA-256: c952ce87c840fd655b6b64a4ff63ec5dcf0c822d2f947613e893594af88ae680. This hash authenticates the local extract only; it does not certify that every amendment, table or Gazette footnote has been consolidated.
Rule map
Related sections
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Related Forms
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Finin2min implementation framework
Trigger and scope
Determine whether the facts fall within the Rule heading and linked section. Verify commencement and the tax year involved.
Evidence and control
Preserve the return, statement, report, certificate, computation, source records and acknowledgement relevant to this Rule.
Consequence
Non-compliance may affect computation, exemption, deduction, procedural validity, reporting, recovery, appeal or penalty depending on the governing section.
Transaction application
Identify the actor, event date, governing tax year or reporting period, authority, document version and every cumulative condition. Record why each limb is satisfied, disputed or not applicable.
Authority, consent and execution
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Evidence and retention checklist
Retain source data, approvals, computations, correspondence, filing acknowledgement, payment record, amended filing history and the version of the governing instrument used.
Limitation, forum and remedies
Do not assume a general limitation period. Check the specific Act, Rule, notification, portal window, condonation power, appeal route and judicial treatment applicable to the event date.
Cross-law overlays
Check the Income-tax Act, 2025, transition rules, relevant Schedule, tax treaty, Companies Act, GST, FEMA and accounting treatment where the transaction crosses regimes.
Finin2min Q&A
Is this page the notified Rule?
It contains a local statutory extract, but the linked official source and later amendments control.
What should be verified immediately before use?
Effective date, amendment history, forms or utilities, filing channel, authentication method, due date, fees, transition from the 1962 Rules and any judicial interpretation.
Source and review trail
Use the current official instrument, portal or regulator publication before acting. This panel separates the category authority from page-specific references.
- Official starting point
- www.incometaxindia.gov.in
Page source links
Rule use-check — filing, evidence and currentness
This rule page is a working reference for “Rule 78 - Other method for determination of arm's length price”. Before using it, verify that the current rule/form text, effective date, portal schema and any amendment or corrigendum still match the transaction or filing period.
Before relying on this page
- Confirm the relevant tax year / assessment-year transition and the governing Income-tax Act, 2025 provision.
- Match the current notified form/rule with the live e-Filing utility, schema and instruction set; notification and portal availability are separate checks.
- Retain computation, supporting schedules, acknowledgements and source documents used for every material field.
Current primary-source checkpoint
Verify against the current official source. Reviewed 22 August 2026; later amendments and portal releases can change the workflow.