Part DCA - Safe Harbour Rules for income referred to in clause (i) of sub-section (1) of section 9 chargeable to tax under the head (From Rule 10TI to Rule 10TIC)
Advance pricing agreement definitions clarify covered transactions, critical assumptions, and transfer pricing methods under the APA framework. Advance pricing agreement expressions are defined for the purposes of Rule 10F and the connected rules governing the Advance Pricing Agreement Scheme. The rule identifies the agreement, application, applicant, unilateral, bilateral and multilateral agreements, the competent authority in India, the covered transaction, the team, and the rollback year. It also explains critical assumptions, the most appropriate transfer pricing method, and the meaning of tax treaty for the APA framework.
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 definitions clarify covered transactions, critical assumptions, and transfer pricing methods under the APA framework.
Advance pricing agreement expressions are defined for the purposes of Rule 10F and the connected rules governing the Advance Pricing Agreement Scheme. The rule identifies the agreement, application, applicant, unilateral, bilateral and multilateral agreements, the competent authority in India, the covered transaction, the team, and the rollback year. It also explains critical assumptions, the most appropriate transfer pricing method, and the meaning of tax treaty for the APA framework.
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