Advance pricing agreement definitions clarify transfer pricing terms, treaty-based arrangements, and the framework for APA applications. Defines the expressions used for advance pricing agreement matters under the Income-tax Rules, 2026, for rule 103 and rules 104 to 120. The definitions cover agreement, application, applicant, covered transaction, critical assumptions, most appropriate transfer pricing method, rollback year, tax treaty, and the composition of the advance pricing agreement team. It also distinguishes between unilateral, bilateral, and multilateral agreements, and identifies the competent authority of India as the authorised officer for functions relating to agreements entered into under the Act.
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 definitions clarify transfer pricing terms, treaty-based arrangements, and the framework for APA applications.
Defines the expressions used for advance pricing agreement matters under the Income-tax Rules, 2026, for rule 103 and rules 104 to 120. The definitions cover agreement, application, applicant, covered transaction, critical assumptions, most appropriate transfer pricing method, rollback year, tax treaty, and the composition of the advance pricing agreement team. It also distinguishes between unilateral, bilateral, and multilateral agreements, and identifies the competent authority of India as the authorised officer for functions relating to agreements entered into under the Act.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.