Circular No. 14/2001 (TP) — ALP methods — CUP, RPM, CPM, TNMM, PSM
Date: 2001-01-01 Status: ACTIVE Category: Transfer Pricing Binding on Department: Yes (Section 119 / Section 400 IT Act 2025)
Summary
Explains the five prescribed methods for determination of arm’s length price.
Key Directions
- Most appropriate method based on nature of transaction.
- CUP preferred where reliable comparable data available.
- TNMM most commonly used.
- PSM appropriate for highly integrated transactions.
Applicability Under IT Act 2025
Saving Clause: Section 536 of IT Act 2025 saves circulars issued under the 1961 Act “so far as not inconsistent” with the new Act.
| Old Section (1961 Act) | New Section (2025 Act) | Consistent? |
|---|---|---|
| 92C | 165 | Yes |
Cross-References
Act Sections
- Section 92C
- Section 165
Related Circulars
- None identified
Key Case Law (Circular Supremacy)
- To be populated — cases where this circular was cited/applied
Full Text
Full text to be added — see raw/circulars/ for PDF when available
Source
- Official: incometaxindia.gov.in/circulars