Quick Summary
The Government has proposed a clarificatory amendment on the manner of computing the 60-day period available to the Transfer Pricing Officer (TPO) for passing an order under section 92CA of the Income-tax Act. This clarification aims to align legislative intent with administrative practice and bring certainty to an area that has seen extensive litigation over the years. Background: Section 92CA and the 60-Day Rule Section 92CA of the Income-tax Act, 1961 empowers the Assessing Officer (AO)
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FAQ :
The main purpose is to clarify how the 60-day period for Transfer Pricing Officers (TPOs) to pass orders under section 92CA of the Income-tax Act is computed, aiming to reduce litigation and bring certainty.
The amendment clarifies that the date of limitation for the completion of assessment is to be included when computing the 60-day period available to the TPO.
The clarification in the Income-tax Act, 1961, will have retrospective effect from 1 June 2007. Parallel amendments in the upcoming Income-tax Act, 2025, will take effect from 1 April 2026.
Yes, the retrospective application from 1 June 2007 is intended to validate past TPO orders that were passed in accordance with the legislative intent, even if they were previously annulled due to differing interpretations.
Yes, the clarification is proposed to apply notwithstanding any judgment, order, or decree of any court, thereby overriding contrary judicial interpretations.
Yes, parallel amendments are proposed in the Income-tax Act, 2025, to ensure consistency and prevent similar disputes under the new law, which comes into effect from 1 April 2026.
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