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Reference to Transfer Pricing Officer (TPO) Section 92CA

Income Tax - Transfer Pricing - International + Domestic - 07 - (1)]: Where any person, being the assessee, has entered into an international 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 under section 92C to the Transfer Pricing Officer. (also apply in specif .....

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) TPO empowered to determine arm s length price of other international transactions of the assessee even though not covered under the reference made to him [Section 92CA(2A) inserted by the Finance Act, 2011 ] 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 .....

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s Chapter shall apply as if such transaction is an international transaction referred to him under section 92(1). Section 92CA(2B) not applicable to proceedings completed before 1.7.2012 [Section 92CA(2C)] Nothing contained in section 92CA(2B) shall empower the Assessing Officer either to assess or reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year, .....

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sfer Pricing Officer shall, by order in writing, determine the arm s length price in relation to the international transaction in accordance with section 92C(3) and send a copy of his order to the Assessing Officer and to the Assessee. TPO to pass order at any time before 60 days prior to limitation period referred to in section 153 or 153B [Section 92CA(3A)]: Where a reference under section 92CA(3) has not been made by the Transfer Pricing Officer before the said date, or a reference under sect .....

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