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

Income Tax - Transfer Pricing - International + Domestic - 07 - (1) Where any person, being the assessee, has entered into an international transaction or specified domestic transaction in any previous year, and the Assessing Officer considers it necessary or expedient so to do, he may, with the previous approval of the Principal Commissioner or Commissioner, refer the computation of the arm s length price in relation to the said international transaction or specified domestic transaction u/s 92 .....

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to determine arm s length price of other international transactions of the assessee even though not covered under the reference made to him Where any other international transaction [other than an international transaction referred under section 92CA(1)], comes to the notice of the Transfer Pricing Officer during the course of the proceedings before him, the provisions of this Chapter shall apply as if such other international transaction is an international transaction referred to him under se .....

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ed 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 .....

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rior to limitation period referred u/s 153 or u/s 153B : Where a reference under section 92CA(3) has not been made by the TPO before the said date, or a reference under section 92CA(1) is made on or after 1.6.2007, an order under section 92CA(3) may be made at any time before 60 days prior to the date on which the period of limitation referred u/s 153 or as the case may be u/s 153B for making the order of assessment or reassessment or recomputation or fresh assessment, as the case may be, expire .....

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