TMI BlogAdvance Pricing Agreement - Section 92CCX X X X Extracts X X X X X X X X Extracts X X X X ..... od of time in future. The APA offers better assurance on transfer pricing methods and are conducive in providing certainity and unanimity of approach. Power provided to CBDT The Board, with the approval of the Central Government may enter into an advance pricing agreement with any person, (a) determining the arm s length price or specifying the manner in which arm s length price ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ice of any international transaction, which is covered under such APA, shall be determined in accordance with the APA so entered into. The provisions of section 92C or 92A which normally apply for determination of arm s length price will be modified to this extent. As a consequence, arm s length price shall be determined in accordance with APA. [ Section 92CC(3) ] Validity of APA ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... [ Section 92CC(6) ] APA can declared Void ab initio Situation - The board may, with the approval of the Central government, by an order, declare an agreement to be void ab initio, if it finds that the agreement has been obtained by the person by fraud or misrepresentation of facts. [ Section 92CC(7) ] Consequences - Upon declaring the agreement void ab initio,---- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s of this section, prescribe a scheme specifying therein the manner, form, procedure and any other matter generally in respect of the advance pricing agreement. [ Section 92CC(9) ] Agreement so entered may also be made applicable for international transactions entered into in maximum four preceding previous years [ Section 92CC(9A) ] Where an application is made by a person for entering ..... X X X X Extracts X X X X X X X X Extracts X X X X
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