The CBDT has issued Instruction No. 15/2015 dated 16.10.2015 in which it has set out revised and updated guidance for implementation of transfer pricing provisions. The Instruction sets out the circumstances in which a reference can be made to the TPO by the AO, the role of the TPO when such a reference is made, the role of the AO after determination of the ALP by the TPO, etc. The Instruction is of crucial importance to all taxpayers and professionals engaged in the practice of transfer pricing law
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