Arm's length price adjustment requires recomputation of prior years' income to reflect transfer pricing determinations. Where the arm's length price is determined under section 92CA and the Transfer Pricing Officer has validated an assessee's option under sub-section (3B) for two consecutive years, the Assessing Officer must recompute the assessee's total income for those two years by amending the assessment order or intimation under section 143(1) to conform with the arm's length price determined under section 92CA(4A) and by accounting for directions under section 144C(5). The recomputation must generally be completed within three months from the end of the month in which the assessment for the relevant year is completed, with an alternative three month period triggered if the requisite orders or intimations are made later.
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Provisions expressly mentioned in the judgment/order text.
Arm's length price adjustment requires recomputation of prior years' income to reflect transfer pricing determinations.
Where the arm's length price is determined under section 92CA and the Transfer Pricing Officer has validated an assessee's option under sub-section (3B) for two consecutive years, the Assessing Officer must recompute the assessee's total income for those two years by amending the assessment order or intimation under section 143(1) to conform with the arm's length price determined under section 92CA(4A) and by accounting for directions under section 144C(5). The recomputation must generally be completed within three months from the end of the month in which the assessment for the relevant year is completed, with an alternative three month period triggered if the requisite orders or intimations are made later.
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