Section 21 - Amendment of section 92CA.

Arm's length price extension: option binds two consecutive years when validated by Transfer Pricing Officer, triggering recomputation.

The amendment provides that an arm's length price determined for a previous year shall apply to similar international or specified domestic transactions for the two consecutive previous years if the assessee files prescribed option(s) and the Transfer Pricing Officer, within one month from the end of the month in which such option(s) are exercised, issues a written declaration validating the option(s); upon such declaration the Transfer Pricing Officer shall determine the arm's length price for those two years and the Assessing Officer shall recompute total income for those years accordingly.