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of <h1>Advance Pricing Agreements under Section 92CC: binding APAs set arm's-length prices, five-year term, prior-year relief, void for fraud</h1> The tax authority, with central government approval, may enter into an advance pricing agreement (APA) with a taxpayer to determine the arm's-length price for international transactions or the income attributable to Indian operations of a non-resident, specifying methods (including statutory methods or rules) and adjustments. An APA is binding on the taxpayer and the relevant tax commissioner and subordinate authorities for up to five consecutive years and may cover up to four prior years subject to conditions. The APA ceases to bind if law or facts change; it may be declared void ab initio for fraud, with ordinary Act provisions and limitation-period adjustments applying. The authority may prescribe procedural schemes, and an APA application renders proceedings pending.
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