Advance pricing agreement binds taxpayer and tax authorities and mandates filing of a modified return reflecting the agreement. New sections introduce a statutory Advance Pricing Agreement regime empowering the Board, with Central Government approval, to enter APAs that determine or prescribe methods for the arm's length price. An APA is binding on the taxpayer and tax authorities for specified transactions and periods (not exceeding five years), subject to non binding effect where law or facts change and voiding for fraud. The Board may prescribe procedural scheme; an APA application renders proceedings pending. Section 92CD requires filing a modified return consistent with the APA and mandates assessment or reassessment in accordance with the APA, with specified time limit adjustments.
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Provisions expressly mentioned in the judgment/order text.
Advance pricing agreement binds taxpayer and tax authorities and mandates filing of a modified return reflecting the agreement.
New sections introduce a statutory Advance Pricing Agreement regime empowering the Board, with Central Government approval, to enter APAs that determine or prescribe methods for the arm's length price. An APA is binding on the taxpayer and tax authorities for specified transactions and periods (not exceeding five years), subject to non binding effect where law or facts change and voiding for fraud. The Board may prescribe procedural scheme; an APA application renders proceedings pending. Section 92CD requires filing a modified return consistent with the APA and mandates assessment or reassessment in accordance with the APA, with specified time limit adjustments.
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