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Roll Back of the Agreement.

Rule 10MA - Rule - Part D. - Special cases - Income Tax - Rule 10MA - 1[ 10 MA. (1) Subject to the provisions of this rule, the agreement may provide for determining the arm s length price or specify the manner in which arm s length price shall be determined in relation to the international transaction entered into by the person during the rollback year (hereinafter referred to as rollback provision ). (2) The agreement shall contain rollback provision in respect of an international transaction .....

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back provision, in respect of an international transaction, has been requested by the applicant for all the rollback years in which the said international transaction has been undertaken by the applicant; and (v) the applicant has made an application seeking rollback in Form 3CEDA in accordance with sub-rule (5); (3) Notwithstanding anything contained in sub-rule (2), rollback provision shall not be provided in respect of an international transaction for a rollback year, if,- (i) the determinati .....

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on specifies the manner in which arm s length price shall be determined in relation to an international transaction undertaken in any rollback year then such manner shall be the same as the manner which has been agreed to be provided for determination of arm s length price of the same international transaction to be undertaken in any previous year to which the agreement applies, not being a rollback year. (5) The applicant may, if he desires to enter into an agreement with rollback provision, fu .....

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