Transfer pricing procedure: specialist officer to determine arm's length price and direct assessment adjustments. The provision allows the Assessing Officer, with prior Commissioner approval, to refer computation of the arm's length price for an international ... Summary
Transfer pricing procedure: specialist officer to determine arm's length price and direct assessment adjustments.
The provision allows the Assessing Officer, with prior Commissioner approval, to refer computation of the arm's length price for an international transaction under section 92C to a Board authorised Transfer Pricing Officer. The Transfer Pricing Officer issues notices for evidence, determines the arm's length price by written order after hearing the assessee and considering relevant materials, may amend orders to rectify apparent mistakes (applying section 154), and may exercise specified inquiry powers; the Assessing Officer must compute income and amend assessments in conformity with the Transfer Pricing Officer's order.
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