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 terms may cover transfer pricing methodology, critical assumptions, and binding effect on changed conditions. Terms of an Advance Pricing Agreement may include the covered international transactions, agreed transfer pricing methodology, determination of arm's length price, relevant definitions, critical assumptions, rollback provision, and additional conditions. The agreement is not binding on the Board or the assessee if critical assumptions change or agreed conditions are not met, and its binding effect ceases only on due notice to the other party or parties.
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 terms may cover transfer pricing methodology, critical assumptions, and binding effect on changed conditions.
Terms of an Advance Pricing Agreement may include the covered international transactions, agreed transfer pricing methodology, determination of arm's length price, relevant definitions, critical assumptions, rollback provision, and additional conditions. The agreement is not binding on the Board or the assessee if critical assumptions change or agreed conditions are not met, and its binding effect ceases only on due notice to the other party or parties.
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