Advance pricing agreements determine arm's length price and bind taxpayer and tax authorities under prescribed procedural rules. Insertion creates an APA framework allowing the Board, with Central Government approval, to enter into agreements determining arm's length price or its method for international transactions; APAs bind the taxpayer and the Commissioner, are valid for up to five consecutive previous years, may be declared void ab initio for fraud or misrepresentation with specified limitation-period consequences, and require taxpayers to file modified returns limited to the APA, with Assessing Officers obliged to assess or reassess in accordance with the APA and with prescribed timelines and extensions for pending proceedings.
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 agreements determine arm's length price and bind taxpayer and tax authorities under prescribed procedural rules.
Insertion creates an APA framework allowing the Board, with Central Government approval, to enter into agreements determining arm's length price or its method for international transactions; APAs bind the taxpayer and the Commissioner, are valid for up to five consecutive previous years, may be declared void ab initio for fraud or misrepresentation with specified limitation-period consequences, and require taxpayers to file modified returns limited to the APA, with Assessing Officers obliged to assess or reassess in accordance with the APA and with prescribed timelines and extensions for pending proceedings.
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