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of <h1>Transfer Pricing Amendment: Two-Year Validity for Arm's Length Price Determinations Under Section 92CA Starting April 2026</h1> The amendment to Section 92CA of the Income-tax Act introduces provisions effective from April 1, 2026, allowing arm's length price determinations for international or specified domestic transactions to apply for two consecutive years following the initial assessment. Taxpayers may exercise this option under specific conditions, with the Transfer Pricing Officer required to validate it within one month. The amendment eliminates the need for separate references in years where valid options exist. The Board may issue guidelines to resolve implementation difficulties, subject to parliamentary approval, with such guidelines requiring presentation before Parliament for potential modification or rejection.
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