Amendment of section 155.47. In section 155 of the Income-tax Act, after sub-section (20), the following sub-section shall be inserted with effect from the 1st April, 2026, namely:-"(21) Where the arm's length price is determined in relation to an international transaction or a specified domestic transaction under sub-section (
3) of section 92CA for any previous year and the Transfer Pricing Officer has declared that an option exercised by the assessee is valid under sub-section (3B) of the said section in respect of such transaction for two consecutive previous years immediately following such previous year, the Assessing Officer shall proceed to re-compute the total income of the assessee for the said two consecutive previous years, by amending the order of assessment or any intimation or deemed intimation under sub-section (1) of section 143, as the case may be,-
| (a) | - | in conformity with the arm's length price so determined by the Transfer Pricing Officer under sub-section (4A) of the said section in respect of such transaction; and |
| (b) | - | taking into account the directions issued under sub-section (5) of section 144C, if any, for such previous year, |
within three months from the end of the month in which the assessment is com
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