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 agreement types and core terms shaping pre agreed transfer pricing arrangements. Definitions for the Advance Pricing Agreement scheme specify the APA as an agreement between the Board and an applicant approved by the Central Government; classify agreements as bilateral, multilateral or unilateral linked to competent authority arrangements; define the covered transaction, the APA team, the most appropriate transfer pricing method, critical assumptions that may void continued application, rollback year within the allowable prior year span, and tax treaty for double taxation avoidance, thereby framing the operative scope and application of APA rules.
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 agreement types and core terms shaping pre agreed transfer pricing arrangements.
Definitions for the Advance Pricing Agreement scheme specify the APA as an agreement between the Board and an applicant approved by the Central Government; classify agreements as bilateral, multilateral or unilateral linked to competent authority arrangements; define the covered transaction, the APA team, the most appropriate transfer pricing method, critical assumptions that may void continued application, rollback year within the allowable prior year span, and tax treaty for double taxation avoidance, thereby framing the operative scope and application of APA rules.
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