Quick Summary
Determination of Arms Length Price in respect of specified domestic transactions in proceedings before Transfer Pricing Officer Section 92CA of the Act provides that the Assessing Officer, if he considers it necessary or expedient to do so, may with the previous approval of Principal Commissioner or the Commissioner, refer the matter of determination of Arms Length Price (ALP) in respect of an international transaction or specified domestic transaction (SDT) to the Transfer Pricing Officer (TPO
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FAQ :
New rules are being introduced to allow the Transfer Pricing Officer (TPO) to determine the Arm's Length Price (ALP) for specified domestic transactions (SDTs) that have not been referred to them by the Assessing Officer or where the audit report has not been filed.
These amendments will take effect from April 1, 2025, and will apply to the assessment year 2025-26 and subsequent assessment years.
The Transfer Pricing Officer (TPO) will be able to deal with specified domestic transactions (SDTs) that have not been referred to them by the Assessing Officer or in respect of which the audit report has not been filed.
The Arm's Length Price (ALP) is the price determined for a transaction between independent parties, used to ensure fair pricing in domestic and international transactions.
A Specified Domestic Transaction (SDT) refers to certain domestic transactions undertaken by a taxpayer that are subject to transfer pricing regulations.
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