Advance Pricing Agreement: allows APAs to determine arm's length price for prior transactions within a prescribed retrospective window. The amendment permits an Advance Pricing Agreement to determine or prescribe the manner of determining the arm's length price for international transactions entered into during a specified retrospective period immediately preceding the APA's first operative year, subject to prescribed conditions, procedure and manner, and provides that where the APA so provides the arm's length price of such past transactions shall be determined in accordance with the APA.
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: allows APAs to determine arm's length price for prior transactions within a prescribed retrospective window.
The amendment permits an Advance Pricing Agreement to determine or prescribe the manner of determining the arm's length price for international transactions entered into during a specified retrospective period immediately preceding the APA's first operative year, subject to prescribed conditions, procedure and manner, and provides that where the APA so provides the arm's length price of such past transactions shall be determined in accordance with the APA.
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