
Introduction The Government has introduced critical amendments to transfer pricing regulations aimed at streamlining the process of determining Arm’s Length Price (ALP) while reducing excessive compliance burdens. These new provisions establish a multi-year ALP determination framework, eliminating

A key element of international tax law, transfer pricing guarantees that transactions between related parties are carried out at arm’s distance to stop profit shifting and tax evasion. Section 92CA of the Income Tax Act, 1961 describes