Arm's length price rollback provisions govern eligibility, exclusions, and filing requirements for international transactions. Roll-back provisions in an advance pricing agreement may determine the arm's length price, or the manner of its determination, for an international transaction during rollback years, subject to specified conditions. The transaction must be the same as the transaction covered by the agreement, the relevant return and transfer pricing report must have been furnished within time, rollback must be sought for all rollback years, and the request must be made in Form No. 51 in accordance with the prescribed procedure. Rollback is unavailable where the year has already been the subject of an appeal before the Appellate Tribunal or where it would reduce declared income or increase declared loss.