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Introducing the βIn Favour Ofβ filter in Case Laws.
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<h1>New Transfer Pricing Guidelines: Roles of AO and TPO in Arm's Length Price Determination u/ss 92 to 92F.</h1> The revised guidelines for implementing transfer pricing provisions under the Income-tax Act, specifically Sections 92 to 92F. It replaces a previous instruction from 2003, addressing changes in legislation and procedures related to international transactions and specified domestic transactions. The guidance details the roles of the Assessing Officer (AO) and Transfer Pricing Officer (TPO) in determining the Arm's Length Price (ALP) for transactions between associated enterprises. It emphasizes procedural requirements, including the need for AO approval before referring cases to the TPO, and outlines the TPO's responsibilities in assessing and documenting ALP determinations. The instruction is effective immediately, superseding prior guidance.