Modified returns under unilateral advance pricing agreements require pending assessments to conform to agreed transfer-pricing terms.

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....Section 92CD(3) requires an assessment for a year covered by a unilateral advance pricing agreement to be completed in accordance with that agreement when proceedings remain pending and a modified return is filed. For AY 2022-23, compliance with the UAPA and filing of the modified return meant that retaining the original transfer-pricing adjustment without considering the modified return was erroneous. The assessment must be completed after taking the modified return into account and applying the UAPA terms and conditions.....