Transfer Pricing Revision Powers Clarified: Principal Commissioners Can Act on TPO Orders from April 2022, Invalid Orders Quashed.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....The Principal Commissioner or Commissioner having jurisdiction over transfer pricing matters has been empowered, effective April 1, 2022, to invoke revisionary action u/s 263 regarding orders passed by the Transfer Pricing Officer (TPO) under their administrative control. The amendment aimed to resolve confusion over revisionary powers concerning TPO orders, particularly after the 2014 notification defining the command chain from Principal Chief Commissioner (International Taxation) to Deputy/Assistant Commissioner (Transfer Pricing). The lawmaker included the "Transfer Pricing Officer" alongside the Assessing Officer for revisionary orders by the respective Principal Commissioner or Commissioner. When statutory provisions are unambiguous, .........