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of <h1>New rule requires most appropriate OECD transfer-pricing method, 3% tolerance; AO can set arm's-length price under s.171(3). (3)</h1> The provision codifies OECD-style transfer-pricing methods, requires selection and application of the 'most appropriate method,' allows acceptance of the actual transaction price within a notified tolerance (up to 3%), and empowers the Assessing Officer to determine arm's-length price during assessment where documentation or data are deficient, subject to a prior show-cause notice; income enhancements from such determination are not deductible and adjustments do not automatically re-compute the counterparty's income where tax was deducted at source. Key changes from the Bill to the Act include a shifted cross-reference for record-keeping, addition of section 171(3) to notice triggers, and minor drafting clarifications tying prescription powers to the Board.
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