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Section 92CC - Advance Pricing Agreement

Income Tax - Transfer Pricing - International + Domestic - 12 - Meaning of Advance Pricing Agreement (APA) Advance Pricing Agreement is an agreement between a tax payer and a taxing authority on an appropriate transfer pricing methodology for a set o .....

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r into an advance pricing agreement with any person, determining the arm s length price or specifying the manner in which arm s length price is to be determined, in relation to an international transaction to be entered into by that person. (2) The m .....

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92C or section 92CA, the arm s length price 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 determinatio .....

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o case shall exceed 5 consecutive previous years. (5) Binding nature of APA The advance pricing agreement entered into shall be binding- On the person in whose case, and in respect of the transaction in relation to which, the agreement has been enter .....

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ferred to in section 92CC(1) shall not be binding if there is a change in law or facts having bearing on the agreement so entered. (7) The board may, with the approval of the Central government, by an order, declare an agreement to be void ab initio, .....

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ly to the person as if such agreement had never been entered into; and Not withstanding anything contained in the Act, for the purpose of computing any period of limitation under this Act, the period beginning with the date of such agreement and endi .....

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