https://www.taxtmi.com/circulars?id=54333 Determination of the Arm's Length Price requires Assessing Officers to refer cases to the Transfer Pricing Officer only in prescribed circumstances: mandatory referral when cases are selected on transfer pricing risk parameters; referral where transactions are undeclared or omitted from the accountant's report; where past transfer pricing adjustments are significant and contested; or where transfer pricing issues arise from search, seizure or survey. The AO must record satisfaction of potential income effect and afford the taxpayer an opportunity to be heard before seeking approval to refer. The TPO must determine ALP using the prescribed methods, issue speaking orders with reasons and data, and maintain detailed records. en-us Thu, 10 Mar 2016 00:00:00 +0530 Fri, 07 Jun 2024 15:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=54333 Determination of the Arm's Length Price requires Assessing Officers to refer cases to the Transfer Pricing Officer only in prescribed circumstances: mandatory referral when cases are selected on transfer pricing risk parameters; referral where transactions are undeclared or omitted from the accountant's report; where past transfer pricing adjustments are significant and contested; or where transfer pricing issues arise from search, seizure or survey. The AO must record satisfaction of potential income effect and afford the taxpayer an opportunity to be heard before seeking approval to refer. The TPO must determine ALP using the prescribed methods, issue speaking orders with reasons and data, and maintain detailed records. Circulars Income Tax Thu, 10 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/circulars?id=54333