TaxTMI 
TaxTMI 
Reference to Transfer Pricing Officer (TPO) - Section 92CA
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.... 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 section 92CA(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 section 92CA(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. Inserted vide Section 21 of the Finance Act, 2025 ] [ S....
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.... him, the provisions of this Chapter shall apply as if such other international transaction is an international transaction referred to him u/s 92CA(1). [ Section 92CA(2A) ] (2B) Provisions of transfer pricing shall also apply to international transaction for which report u/s 92E is not furnished by the assessee From 01.04.2025 - Where in respect of an international transaction or a specified domestic transaction, the assessee has not furnished the report u/s 92E and such transaction comes to the notice of the Transfer Pricing Officer during the course of the proceeding before him, the provisions of this Chapter shall apply as if such transaction is an international transaction or a specified domestic transaction ref....
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....t any time before 60 days prior to limitation period referred u/s 153 or u/s 153B : Where a reference u/s 92CA(3) has not been made by the TPO before the said date, or a reference under section 92CA(1) is made on or after 1.6.2007, an order u/s 92CA(3) may be made at any time before 60 days prior to the date on which the period of limitation referred u/s 153 or as the case may be u/s 153B for making the order of assessment or reassessment or recomputation or fresh assessment, as the case may be, expires. Provided that in the circumstances referred to in clause (ii) or clause (x) of Explanation (1) to section 153, if the period of limitation available to the Transfer Pricing Officer for making an order is less than sixty days, such remainin....
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....nsfer Pricing Officer. It may be observed from the above that it will be mandatory for the Assessing Officer to compute the total income on the basis of arm's length price determined by the Transfer Pricing Officer. [ Section 92CA(4) ] [(4A) Notwithstanding anything contained in section 92CA(4), where the Transfer Pricing Officer has declared an option exercised by the assessee as valid option under section 92CA(3B), he shall examine and determine the arm's length price in relation to such similar transaction for two consecutive previous years immediately following such previous year, in the order referred to in section 92CA(3) and on receipt of such order, the Assessing Officer shall proceed to recompute the total income of the assessee f....