Arm's length price determination: Transfer Pricing Officer may be referred to set binding price, triggering conformity in assessment. Assessing Officers may refer determination of the arm's length price for international or specified domestic transactions to a Transfer Pricing Officer with prior approval; the Transfer Pricing Officer issues notice, hears evidence, determines the arm's length price by order and sends it to the AO and assessee, after which the AO computes total income in conformity. A declared valid option permits the determined arm's length price to apply to two subsequent tax years subject to prescribed exercise of option and TPO declaration; rectification, specified powers, limitation extensions and guideline-making for difficulties are provided.
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: Transfer Pricing Officer may be referred to set binding price, triggering conformity in assessment.
Assessing Officers may refer determination of the arm's length price for international or specified domestic transactions to a Transfer Pricing Officer with prior approval; the Transfer Pricing Officer issues notice, hears evidence, determines the arm's length price by order and sends it to the AO and assessee, after which the AO computes total income in conformity. A declared valid option permits the determined arm's length price to apply to two subsequent tax years subject to prescribed exercise of option and TPO declaration; rectification, specified powers, limitation extensions and guideline-making for difficulties are provided.
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