Comparison of Section 166 'Reference to Transfer Pricing Officer.' between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

Reference to Transfer Pricing Officer centralises arm's length price determination, binding assessments and enabling validated multi year application.

An Assessing Officer, with prior supervisory approval, may refer determination of the arm's length price for international or specified domestic transactions to a designated Transfer Pricing Officer who issues a written order after notice and hearing; that TPO order is binding on the Assessing Officer for computing total income, and an opt in permits validated application of the TPO's determination to the two immediately following tax years subject to prescribed conditions and recomputation procedures.