Advance Pricing Agreement secures agreed transfer pricing methodology and binds taxpayer and tax authorities unless law or facts change. Advance pricing agreements allow the Board, with Central Government approval, to determine an arm's length price or the manner to determine income attributable to operations in India by or on behalf of a non-resident; APAs may adopt methods in section 92C or rules, prevail over sections 92C/92CA for covered transactions, be valid up to five years (and may cover up to four preceding years), be binding on the taxpayer and Principal Commissioner/Commissioner and subordinate authorities, cease to bind on change in law or facts, may be void ab initio for fraud or misrepresentation with limitation-period consequences, and are subject to a prescribed procedural scheme while applications are deemed pending.