TaxTMI 
TaxTMI 
Exercise of option for determination of arm’s length price for multiple years in a single proceeding
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.... price for multiple year in a single proceeding by furnishing Form No. 46 for two consecutive tax years (the second tax year and the third tax year, respectively) immediately following the tax year (the first tax year) in respect of which reference has been made in its case under the said section. (2) The Form No. 46, in respect of international transactions or specified domestic transactions s....
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....ctions or the specified domestic transactions (herein referred to as the relevant transactions) in the second and third tax year for which option or options has been exercised in Form No. 46, should be similar to the international transactions or the specified domestic transactions in the first tax year; (b) the relevant transactions shall be treated to be similar, if they satisfy the fol....
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....ansaction and no material change in the functions performed, taking into account assets employed and the risks assumed; and (v) there is no change in the contractual terms (whether or not such terms are formal or in writing) of the relevant transactions, which explicitly or implicitly laid down how the responsibilities, risks and benefits are to be divided between the parties to the relev....
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....he associated enterprises relevant to the transactions is a resident of a jurisdiction which has been notified under section 176. (6) If the assessee objects to the order of the Transfer Pricing Officer under sub-rule (4) declaring the option to be invalid, it may file its objections with the Commissioner, to whom the Transfer Pricing Officer is subordinate, within fifteen days of receipt of th....