Section 92CA Update: Assessing Officer Must Follow Transfer Pricing Officer's Order on Arm's Length Price, Not Transaction Occurrence.

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....Determination of transaction - statutory change to section 92CA - AO is now bound by the order of the TPO on the computation of the arm’s length price of an international transaction, the Assessing Officer is not and cannot be stated to be bound by the opinion of the TPO with respect to the question whether there had, in fact, been an international transaction between the assessee and the associated person during the period under consideration. .... - HC....