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of <h1>Union Budget 2025-26: Amendments Proposed for Transfer Pricing to Simplify Arm's Length Price Determination</h1> The Union Budget 2025-26 proposes amendments to transfer pricing provisions to streamline the determination of arm's length prices (ALP) for international and specified domestic transactions. The changes aim to reduce repetitive compliance by allowing ALP determined for a given year to apply to similar transactions in the following two years. This involves the assessee opting for this provision, subject to validation by the Transfer Pricing Officer (TPO). The TPO will then determine and apply the ALP for these years, and the Assessing Officer will recompute the assessee's income accordingly. These amendments will be effective from April 1, 2026, for the assessment year 2026-27 onwards.
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