https://www.taxtmi.com/circulars?id=53953 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. en-us Fri, 16 Oct 2015 00:00:00 +0530 Tue, 20 Oct 2015 14:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=53953 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. Circulars Income Tax Fri, 16 Oct 2015 00:00:00 +0530 https://www.taxtmi.com/circulars?id=53953