TRANSFER PRICING
- Introduce a “Roll Back” provision in the APA (Advance Pricing Agreement) scheme so that an APA entered into for future transactions may also be applied to international transactions undertaken in previous four years in specified circumstances.
- Introduction of ‘range concept’ for determining Arm’s Length Price (ALP)
- Transfer pricing rules and regulation has been amended to allow use of multiple year data as comparable rather than single year data as of now.
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