Arm's Length Price determination directs transfer pricing referrals to specialized officers, defining AO and TPO roles and procedures. Guidance clarifies that determination of the Arm's Length Price for international transactions is made by the Transfer Pricing Officer upon reference by the Assessing Officer, who must compute total income in conformity with the ALP. The AO may rely on Form 3CEB to form a prima facie belief, must record satisfaction and afford a hearing in cases of non filing, non disclosure or contested applicability, obtain higher level approval before referral, and refrain from referrals based solely on transaction value when cases are selected on risk parameters.
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 directs transfer pricing referrals to specialized officers, defining AO and TPO roles and procedures.
Guidance clarifies that determination of the Arm's Length Price for international transactions is made by the Transfer Pricing Officer upon reference by the Assessing Officer, who must compute total income in conformity with the ALP. The AO may rely on Form 3CEB to form a prima facie belief, must record satisfaction and afford a hearing in cases of non filing, non disclosure or contested applicability, obtain higher level approval before referral, and refrain from referrals based solely on transaction value when cases are selected on risk parameters.
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