Transfer pricing adjustments: specified domestic transactions treated like international transactions for penalty deeming consequences under transfer pricing rules.

The amendment extends the deeming provision so that amounts added or disallowed due to transfer pricing adjustments in specified domestic transactions are treated like those from international transactions and deemed to represent concealed or inaccurately furnished income, unless the assessee satisfies the tax authorities that the price was computed in good faith and with due diligence in accordance with transfer pricing provisions and the prescribed manner.

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