Arm's length price determination by Transfer Pricing Officer enables binding computation and reporting where assessee fails to cooperate. The Assessing Officer may refer computation of the arm's length price to a Transfer Pricing Officer, who may require the assessee to attend or produce evidence and documents; the TPO must determine the arm's length price after considering the assessee's evidence and material obtained following an opportunity to be heard, may make a best judgement determination if the assessee does not cooperate, and must report the determination to the Assessing Officer and the assessee, subject to a statutory time limit and available inspection and inquiry powers.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Arm's length price determination by Transfer Pricing Officer enables binding computation and reporting where assessee fails to cooperate.
The Assessing Officer may refer computation of the arm's length price to a Transfer Pricing Officer, who may require the assessee to attend or produce evidence and documents; the TPO must determine the arm's length price after considering the assessee's evidence and material obtained following an opportunity to be heard, may make a best judgement determination if the assessee does not cooperate, and must report the determination to the Assessing Officer and the assessee, subject to a statutory time limit and available inspection and inquiry powers.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
