Additional disclosures for TP transactions: Is Revenue drawing the battlelines?

CBDT has amended Form 3CEB, an Accountants Report to be furnished in respect of international transaction and specified domestic transactions (SDT) u/s 92E. In addition to details on SDT, new form also requires specific disclosure including method of determination of ALP for international transactions like guarantee, issue and buy back of shares including transactions specified in Expl 1 below Sec. 92B(2) (inclusive definition of term 'international transaction'). Does this mean that the Revenue has no intention of backing down in Shell type cases? Will this affect in any way the writ petitions already filed by Shell and Vodafone in Bombay HC? Apart from DCF, could there be other benchmarking approaches for ALP determination vis-a-vis issue of shares? 

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