Tag: Transfer Pricing

A tax opinion in 2026 survives less on elegant citation than on facts, disclosure and process. As scrutiny gets more data-rich, defensibility now begins long before the notice arrives.

Section 263 has moved to section 377 under the Income-tax Act, 2025, but the real story is not the renumbering. It is the cleaner limitation machinery, tighter transition rules, and the continuing risk from weak assessment records.