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Board With The Approval Of Central Government Allowed To Enter Into Advance Price Agreement

Income Tax - Transfer Pricing - International + Domestic - 12 - Meaning of Advance Pricing Agreement(APA) [Secs. 92CC AND 92CD] Advance Pricing Agreement is an agreement between a tax payer and a taxing authority on an appropriate transfer pricing methodology for a set of transactions over a fixed period of time in future. The APA offers better assurance on transfer pricing methods and are conducive in providing certainity and unanimity of approach. CBDT MAY ENTER INTO ADVANCE PRICING AGREEMENT .....

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transaction to be entered by that person. HOW TO COMPUTE ALP 92CC(2) The manner of determination of arm s length price in such cases shall be any method including those already provide in section 92C(1), with necessary adjustments or variations. APA TO SUPERSEDE PROVISIONS OF SECTION 92C OR 92A UNDER SECTION 92CC(3) 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 9 .....

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case, and in respect of the transaction in relation to which, the agreement has been entered into; and On the principal commissioner or commissioner, and the income-tax authorities subordinate to him, in respect of the said person and the said transaction. AGREEMENT NOT TO BE BINDING IF THERE IS A CHANGE IN LAW OR FACTS [Section 92CC(6)] The agreement referred 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. AGREEMENT MAY .....

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