Advance Pricing Agreement fixes transfer pricing method and binds taxpayer and authority, subject to change for law or fraud. An Advance Pricing Agreement fixes the arm's length price or the method for determining it for specified international transactions by agreement between a taxpayer and the Board. APAs govern over ordinary statutory provisions for arm's length price, are binding on the taxpayer and tax authorities for the years specified, may be declared void ab initio if obtained by fraud or misrepresentation, and the Board may prescribe the scheme, manner and procedure for APAs and extend applicability to certain preceding years.