Advance pricing agreement pre determines arm's length pricing and binds taxpayer and tax authorities for specified transactions. Advance pricing agreements permit pre determination of the arm's length price or the method for computing income attributable to operations in India by a non resident; such agreements, entered by the Board with Central Government approval and governed by prescribed methods and procedural scheme, shall determine the arm's length price or attributable income for covered transactions and be binding on the taxpayer and income tax authorities for the specified period, subject to non binding on change of law or facts and voidability for fraud or misrepresentation with attendant limitation period consequences.
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 pre determines arm's length pricing and binds taxpayer and tax authorities for specified transactions.
Advance pricing agreements permit pre determination of the arm's length price or the method for computing income attributable to operations in India by a non resident; such agreements, entered by the Board with Central Government approval and governed by prescribed methods and procedural scheme, shall determine the arm's length price or attributable income for covered transactions and be binding on the taxpayer and income tax authorities for the specified period, subject to non binding on change of law or facts and voidability for fraud or misrepresentation with attendant limitation period consequences.
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