Arm's length price determinations now have a fixed pre limitation cut off, and assessments must follow those determinations.

Amendment permits the Transfer Pricing Officer to make determinations until sixty days before the expiry of the relevant assessment limitation period when a reference was made before or after the effective date but the order remains outstanding; on receipt of such an order the Assessing Officer must compute the assessee's total income in conformity with the arm's length price as determined by the Transfer Pricing Officer.

---

---

---