Section 33 : Price transferring and other arrangements between associated persons

1) If any provision is made between the associated persons and the provision is operated as per arm’s length, the Department may, by issuing a notice in writing, distribute, appropriate or allocate the amounts to be included or deducted in computing the income between those persons in such a manner as to reflect the taxable income or the payable tax that could be set for them.

2) In carrying anything mentioned in sub-section (1), the Department may do as follows:-

a) To re-characterise any income, loss, amount or source and type of payment or

b) Where various expenses, including main office expenses, which any person had to incur to operate any business have yielded benefits to the associated person or persons, to allocate such expenses between the associated persons on the comparative basis of the turnover of the business.