Arm's length price rules: notification limit capped and assessee's pricing option restricted where deviation exceeds prescribed threshold. Amendments restrict the Central Government's power to notify permissible variation for deeming the actual transaction price as the arm's length price and clarify that this deeming applies to proceedings pending before an Assessing Officer as of the retrospective date. A new rule denies the assessee's option to select a price deviating from the arithmetical mean where deviation exceeds a prescribed threshold. A further provision prevents these rules from authorising assessments, reassessments, or liability-increasing adjustments for proceedings completed before the retrospective cutoff.
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Arm's length price rules: notification limit capped and assessee's pricing option restricted where deviation exceeds prescribed threshold.
Amendments restrict the Central Government's power to notify permissible variation for deeming the actual transaction price as the arm's length price and clarify that this deeming applies to proceedings pending before an Assessing Officer as of the retrospective date. A new rule denies the assessee's option to select a price deviating from the arithmetical mean where deviation exceeds a prescribed threshold. A further provision prevents these rules from authorising assessments, reassessments, or liability-increasing adjustments for proceedings completed before the retrospective cutoff.
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