Advance pricing agreement: predetermines arm's length pricing method and binds parties to specified transactions under set conditions. The Board, with Central Government approval, may enter into an advance pricing agreement specifying how the arm's length price for an international transaction is to be determined, including use of prescribed methods with adjustments; the agreement governs determination of arm's length price for covered transactions and is valid for specified financial years not exceeding five consecutive years. It is binding only on the taxpayer, only for the specified transaction, and on the Commissioner and subordinate income-tax authorities only in respect of that taxpayer and transaction; the Board may void agreements obtained by fraud or misrepresentation and may frame a Scheme by notification.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Advance pricing agreement: predetermines arm's length pricing method and binds parties to specified transactions under set conditions.
The Board, with Central Government approval, may enter into an advance pricing agreement specifying how the arm's length price for an international transaction is to be determined, including use of prescribed methods with adjustments; the agreement governs determination of arm's length price for covered transactions and is valid for specified financial years not exceeding five consecutive years. It is binding only on the taxpayer, only for the specified transaction, and on the Commissioner and subordinate income-tax authorities only in respect of that taxpayer and transaction; the Board may void agreements obtained by fraud or misrepresentation and may frame a Scheme by notification.
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