Advance Pricing Agreements allow binding determination of arm's length price and attributable income, overriding other transfer-pricing methods. The amendment authorises the Board, with Central Government approval, to enter into advance pricing agreements that determine the arm's length price or the manner of its determination for international transactions, or to determine the income attributable to operations in India by or on behalf of a non-resident. Such APAs may employ methods in section 92C(1) or rule-prescribed methods with adjustments, and the arm's length price or attributable income shall be determined according to the APA notwithstanding sections 92C, 92CA, or rule methods. An APA may cover up to four preceding years subject to prescribed conditions.
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 Agreements allow binding determination of arm's length price and attributable income, overriding other transfer-pricing methods.
The amendment authorises the Board, with Central Government approval, to enter into advance pricing agreements that determine the arm's length price or the manner of its determination for international transactions, or to determine the income attributable to operations in India by or on behalf of a non-resident. Such APAs may employ methods in section 92C(1) or rule-prescribed methods with adjustments, and the arm's length price or attributable income shall be determined according to the APA notwithstanding sections 92C, 92CA, or rule methods. An APA may cover up to four preceding years subject to prescribed conditions.
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