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 rollback provision governs arm's length price determination for covered international transactions with strict filing conditions. Arm's length price determination under an advance pricing agreement may include a rollback provision for international transactions undertaken during rollback years, subject to the same transaction, timely return filing, section 92E reporting, request for all rollback years, and filing of Form 3CEDA with the prescribed additional fee. Rollback is not available where the year was already in appeal before the Appellate Tribunal or where it would reduce declared income or increase declared loss. The same method for determining arm's length price must apply to corresponding earlier covered years, and transitional filing provisions permit revision of the agreement to incorporate rollback within the specified periods.
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 rollback provision governs arm's length price determination for covered international transactions with strict filing conditions.
Arm's length price determination under an advance pricing agreement may include a rollback provision for international transactions undertaken during rollback years, subject to the same transaction, timely return filing, section 92E reporting, request for all rollback years, and filing of Form 3CEDA with the prescribed additional fee. Rollback is not available where the year was already in appeal before the Appellate Tribunal or where it would reduce declared income or increase declared loss. The same method for determining arm's length price must apply to corresponding earlier covered years, and transitional filing provisions permit revision of the agreement to incorporate rollback within the specified periods.
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