Computation of income from international transaction having regard to Arm's Length Price - Section 92 of the Income-tax Act - Reference to Transfer Pricing Officer and his role - Regarding

Arm's Length Price determination centralises transfer pricing references to Transfer Pricing Officers with prescribed AO procedural roles.

The AO may refer identified international transactions with an associated enterprise to a Transfer Pricing Officer who alone shall determine the Arm's Length Price by applying the prescribed methods and the most appropriate method; the TPO must issue a speaking order with reasons and data, provide copies to the AO, and where the AO receives the TPO's order must compute the taxpayer's total income having regard to that Arm's Length Price while affording the taxpayer a formal opportunity to be heard. A register and database of references must be maintained and jurisdictional allocations of TPOs are notified.