Reference to Transfer Pricing Officer

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....r computation of the arm's length price in relation to an international transaction or a specified domestic transaction shall be made, if the Transfer Pricing Officer has declared that option exercised by the assessee in sub-section (3B) in relation to such transaction is valid for such previous year: Provided further that if any reference for an international transaction or a specified domestic transaction, in respect of a previous year, for which the option is declared valid under sub-section (3B) is made before or after such declaration by the Transfer Pricing Officer, the provisions of this sub-section shall have the effect as if no reference is made for such transaction.] (2) Where a reference is made under sub-section (1), ....

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.... section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year, proceedings for which have been completed before the 1st day of July, 2012.] (3) On the date specified in the notice under sub-section (2), or as soon thereafter as may be, after hearing such evidence as the assessee may produce, including any information or documents referred to in sub-section (3) of section 92D and after considering such evidence as the Transfer Pricing Officer may require on any specified points and after taking into account all relevant materials which he has gathered, the Transfer Pricing Officer shall, by order in writing, determin....

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....re the period of limitation expires on 31st of March of any year (not being a leap year), the order under sub-section (3) may be made up to the 30th of January of that year; (b) where the period of limitation expires on 31st of March of any year (being a leap year), the order under sub-section (3) may be made up to the 31st of January of that year; (c) where the period of limitation expires on 31st of December of any year, the order under sub-section (3) may be made up to the 1st of November of that year.] ^19[(3B) The arm's length price, being determined in relation to the international transaction or the specified domestic transaction under sub-section (3) for any previous year shall apply to similar international tra....

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....ficer shall proceed to recompute the total income of the assessee for the said two consecutive previous years as per the provisions of sub-section (21) of section 155.] (5) With a view to rectifying any mistake apparent from the record, the Transfer Pricing Officer may amend any order passed by him under sub-section (3), and the provisions of section 154 shall, so far as may be, apply accordingly. (6) Where any amendment is made by the Transfer Pricing Officer under sub-section (5), he shall send a copy of his order to the Assessing Officer who shall thereafter proceed to amend the order of assessment in conformity with such order of the Transfer Pricing Officer. (7) The Transfer Pricing Officer may, for the purposes of determining....

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....rnment, issue guidelines for the purpose of removing such difficulty: Provided that no such guideline shall be made after the expiration of two years from the 1st April, 2026. (12) Every guideline issued by the Board under sub-section (11) shall be laid before each House of Parliament while it is in session for a total period of thirty days which may be comprised in one session or in two or more successive sessions, and if, before the expiry of the session immediately following the session or the successive sessions aforesaid, both houses agree in making any modification in such guideline or both Houses agree that the guideline, should not be issued, the guideline shall thereafter have effect only in such modified form or be of n....

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....2 8. Inserted vide Section 39 of the Finance Act, 2012 w.e.f. 01-07-2012 9. Substituted vide Section 4 of the Finance (No. 2) Act 2014 w.e.f. 01-06-2013 before it was read as, "Commissioner" 10. Inserted vide Section 47 of the Finance Act 2016 w.e.f. 01-06-2016 11.  Inserted vide Section 4 of the The Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act 2020 w.e.f. 01-11-2020  12. Substituted vide Section 24 of the Finance Act 2022 w.e.f. 01-04-2022 before it was read as, "2022" 13. Substituted vide Section 6 of the Finance Act 2024 w.e.f. 01-04-2024 before it was read as, "^12[2024]" 14. Substituted vide Section....