Transfer pricing thresholds revised to restrict option where pricing variation exceeds notified limit and curb retrospective adjustments. Amendments to section 92C impose a maximum notified percentage cap for a proviso in sub section (2) and clarify that the second proviso applies to assessment or reassessment proceedings pending before the Assessing Officer as of a prior date. Sub section (2A) disqualifies an assessee from using the earlier option where the variation between the arithmetical mean and actual transaction price exceeds a specified threshold. Sub section (2B) restricts the Assessing Officer from using sub section (2A) to open or enhance liability for assessment years with proceedings completed before the stated retrospective date.
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Transfer pricing thresholds revised to restrict option where pricing variation exceeds notified limit and curb retrospective adjustments.
Amendments to section 92C impose a maximum notified percentage cap for a proviso in sub section (2) and clarify that the second proviso applies to assessment or reassessment proceedings pending before the Assessing Officer as of a prior date. Sub section (2A) disqualifies an assessee from using the earlier option where the variation between the arithmetical mean and actual transaction price exceeds a specified threshold. Sub section (2B) restricts the Assessing Officer from using sub section (2A) to open or enhance liability for assessment years with proceedings completed before the stated retrospective date.
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