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of <h1>Taxpayers Can Modify Transfer Pricing Returns Within 3 Months of Advance Pricing Agreement Under Sections 169 and 92CD</h1> A comprehensive legal analysis of Clause 169 of the Income Tax Bill, 2025 and Section 92CD of the Income-tax Act, 1961 reveals a structured approach to implementing Advance Pricing Agreements (APAs). The provisions establish a mechanism for taxpayers to file modified returns within three months of entering an APA, ensuring alignment between agreed transfer pricing methodologies and tax assessments. Both clauses provide clear guidelines for modifying completed or pending assessments, prescribe specific timelines, and aim to reduce litigation while providing certainty in cross-border transactions involving associated enterprises.
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