Arm's length price option prevents TPO reference and extends pricing to two subsequent years when declared valid. The amendments provide that where an assessee exercises a prescribed option and the Transfer Pricing Officer declares that option valid for a previous year, no reference for computation of the arm's length price shall be made for that transaction; the arm's length price determined for a year may apply to similar transactions in the two immediately following years if the assessee files options in prescribed form and the TPO issues a written validity declaration, and where declared valid the TPO will determine prices for those subsequent years and the Assessing Officer will recompute total income accordingly.
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 option prevents TPO reference and extends pricing to two subsequent years when declared valid.
The amendments provide that where an assessee exercises a prescribed option and the Transfer Pricing Officer declares that option valid for a previous year, no reference for computation of the arm's length price shall be made for that transaction; the arm's length price determined for a year may apply to similar transactions in the two immediately following years if the assessee files options in prescribed form and the TPO issues a written validity declaration, and where declared valid the TPO will determine prices for those subsequent years and the Assessing Officer will recompute total income accordingly.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
