Arm's length price determination for multiple years requires Form No. 46, supporting certificate, and prescribed transaction similarity.

Option for determination of arm's length price for multiple tax years in a single proceeding may be exercised by furnishing Form No. 46 for the second and third tax years immediately following the first tax year covered by reference under section 166(9)(a). The form must be filed within the prescribed period ending on 30 June succeeding the third tax year, and must be accompanied by the accountant's certificate in Form No. 47. Where the relevant international or specified domestic transactions satisfy the prescribed similarity and compliance conditions, the Transfer Pricing Officer must decide within one month whether the option is valid or invalid.

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