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CMA Final · Direct Tax Laws and International Taxation · Transfer Pricing

The TPO determined the arm's length price for a tax year under section 166(6). Under section 166(9), the assessee may opt to have that price apply to similar international transactions for how many consecutive tax years immediately following that year?

The arm's length price fixed by the TPO can apply to similar transactions for the two consecutive tax years immediately following, provided the assessee exercises the option in the prescribed manner and the TPO declares the option valid by written order.

  1. AOne
  2. BTwoCorrect
  3. CThree
  4. DFive

Explanation

Section 166(9) states that the arm's length price determined under sub-section (6) shall apply to similar transactions for the two consecutive tax years immediately following, if the assessee exercises the option in the prescribed form, manner and time and the TPO declares it valid. One, three or five years are not provided.

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