The Finance (No. 2) Act, 2014 had amended the provision of Income-tax Act relating to transfer pricing regime. The purpose of amendment of section 92C (2) of the Act was to facilitate introduction of range concept for determination of Arm's Length Price of an international transaction or a specified domestic transaction. Further, use of multiple year data for comparability analysis for the purpose of transfer pricing was also to be incorporated.
The use of multiple year data and range concept in transfer pricing regime is proposed to be incorporated through amendments to be made to Income-tax Rules, 1962.
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