Transfer pricing: unreported international transactions may be treated as referred to the TPO, yet AO reassessment powers restricted.

Section 92CA is amended to replace references to "international transaction" with "international transaction or specified domestic transaction"; a retrospective provision allows the Transfer Pricing Officer to treat unreported international transactions as referred to him when noticed in proceedings; and a later provision limits the Assessing Officer's authority by prohibiting assessment, reassessment, enhancement, refund reduction, or other increases in taxpayer liability for years with proceedings completed before the specified cut off date.

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