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of <h1>CBDT Clarifies TPO Role in International Transactions Over Rs. 5 Crores u/s 92, Ensures Consistent Transfer Pricing Scrutiny.</h1> The circular addresses the computation of income from international transactions concerning Arm's Length Price under Section 92 of the Income-tax Act. It clarifies the role of Transfer Pricing Officers (TPO) in scrutinizing cases where the cumulative value of international transactions exceeds Rs. 5 crores. The Central Board of Direct Taxes (CBDT) approved manual scrutiny to ensure timely and uniform implementation of transfer pricing regulations until suitable computer software is available. The eventual development of software will include these transactions as criteria for scrutiny.
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