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of <h1>Advance Pricing Agreements Set Transfer Pricing Methodology, Override Sections 92C and 92CA, Valid Up to Five Years</h1> An Advance Pricing Agreement (APA) is a contract between a taxpayer and a tax authority to establish a transfer pricing methodology for future transactions, ensuring certainty and consistency. The Central Board of Direct Taxes (CBDT), with government approval, can determine the arm's length price for international transactions and related income. An APA can override sections 92C and 92CA, is valid for up to five years, and is binding unless laws or facts change. It can be voided if obtained through fraud. The Board prescribes procedures for APAs, which can apply to transactions from up to four prior years. APAs are not applicable to specified domestic transactions.
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