Transfer pricing adjustment deemed income unless taxpayer proves arm's length pricing computed in good faith and with due diligence.

The amendment fixes the penalty under section 271 as a sum of ten thousand rupees, replacing the prior range. It inserts Explanation 7 providing that amounts added or disallowed due to transfer pricing adjustments in international transactions are deemed to represent concealed or inaccurately furnished income unless the assessee proves to the Assessing Officer or Commissioner (Appeals) that the price was computed in accordance with transfer pricing provisions and prescribed manner, in good faith and with due diligence.

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