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of <h1>Section 166 lets Assessing Officer refer arm's-length pricing issues to Transfer Pricing Officer for binding determinations and one-year opt-in carryover</h1> Section 166 permits an Assessing Officer, with senior approval, to refer arm's-length pricing issues for international or specified domestic transactions to a designated Transfer Pricing Officer (TPO) who issues binding written determinations after notice and hearing; an opt-in lets a TPO determination for one year be applied to the two immediately following years if prescribed formalities are met and validated by the TPO. Key changes from the Bill to the Act: clearer timing for TPO orders, altered cross-references affecting limitation extensions, removal of a two-year sunset on guideline issuance, and a more specific recomputation reference to section 288(2), reducing drafting ambiguity.
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