Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unchanged.

Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unchanged. https://www.taxtmi.com/highlights?id=104894 Advance Pricing Agreement methodology may guide transfer-pricing benchmarking for an assessment year outside the agreement's term if the FAR analysis and underlying activities do not materially differ from covered years. Where Revenue challenges reliance on that methodology, it must establish the relevant factual distinction. A Transfer Pricing Officer who rejects the taxpayer's benchmarking in favour of the Other Method should apply that method and determine an arm's length price, rather than fixing a nil price on an ad hoc basis. en-us Tue, 13 Oct 2026 10:07:02 +0530 Tue, 13 Oct 2026 10:07:02 +0530 TaxTMI RSS Generator Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unchanged. https://www.taxtmi.com/highlights?id=104894 Advance Pricing Agreement methodology may guide transfer-pricing benchmarking for an assessment year outside the agreement's term if the FAR analysis and underlying activities do not materially differ from covered years. Where Revenue challenges reliance on that methodology, it must establish the relevant factual distinction. A Transfer Pricing Officer who rejects the taxpayer's benchmarking in favour of the Other Method should apply that method and determine an arm's length price, rather than fixing a nil price on an ad hoc basis. Highlights Income Tax Tue, 13 Oct 2026 10:07:02 +0530 https://www.taxtmi.com/highlights?id=104894