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Guidance Note on Report Under Section 92E of the Income Tax Act, 1961 (Transfer Pricing)
April, 10th 2013

Dear Members,

It gives me immense pleasure to inform you that ICAI has recently released the Guidance Note on Report Under Section 92E of the Income Tax Act, 1961 (Transfer Pricing). The law relating to transfer pricing is dynamic and the members of the Institute are getting acquainted with the practical implications of the provisions and rules relating to Transfer pricing. 

The Finance Act, 2012 has made significant changes such as Definition of International Transaction,Advance Pricing Agreement (APA), Amendments relating to Penalties, etc. 

The members of our profession are required to examine the information and documentation so maintained and expresses an opinion thereof in Form No.3CEB as to the compliance of the legal requirements. The report also requires opinion to be expressed about the truth and correctness of the particulars given in the annexure to Form No. 3CEB. 

Guidance has been given with regard to how the Chartered Accountant should exercise due diligence while verifying international transactions in view of the increased scope of the definition of International Transactions. 

For your benefit, the complete text of the Guidance Note along with its Appendices is available on ICAI website at URL:

Complete text of the Guidance Note and its annexures can be downloaded free of cost from this URL.

The published (Book) 2013 Guidance Note is also available for sale at the Regional Council/ Branches. 

Your suggestions on the subject are welcome. 

Warm regards, 

CA. Dhinal A. Shah
Committee on International Taxation,

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