Reference to Transfer Pricing Officer (TPO) - Section 92CA

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... notice: Where a reference is made to the TPO, the TPO shall serve a notice on the assessee requiring him to produce or cause to be produced on a date to be specified therein, any evidence on which the assessee may rely in support of the computation made by him of the arm s length price in relation to such international transaction or specified domestic transaction. (2A) TPO empowered to determine arm s length price of other international transactions or specified domistic transaction of the assessee even though not covered under the reference made to him From 01.04.2025 - Where any other international transaction or specified domestic transaction [other than an international transaction or a specified domestic transaction referred u/s 92CA( .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... saction comes to the notice of the TPO during the course of the proceeding before him, the provisions of this Chapter shall apply as if such transaction is an international transaction referred to him u/s 92(1). (2C) Nothing contained in section 92CA(2B) shall empower the Assessing Officer either to assess or reassess u/s 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee u/s 154, for any assessment year, proceedings for which have been completed before 1.7.2012. (3) TPO to pass order in writing: On the date specified in the above notice, or as soon thereafter as may be,- After hearing such evidence as the assessee may produce, including any information or do .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... the total income of the Assessee u/s 92C(4) in conformity with the arm s length price as so determined by the Transfer Pricing Officer. It may be observed from the above that it will be mandatory for the Assessing Officer to compute the total income on the basis of arm s length price determined by the Transfer Pricing Officer. (5) Rectification of order passed by TPO: With a view to rectifying any mistake apparent from the record, the Transfer Pricing Officer may amend any order passed by him, and the provisions of section 154 shall, so far as may be, apply accordingly. (6) Where any amendment of such order is made by the Transfer Pricing Officer, he shall send a copy of his order to the Assessing Officer who shall thereafter proceed to ame .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X