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Advance Pricing Agreement filings require specified fees, prescribed form, timelines, pre-filing consultation, and competent authority submissions. Advance Pricing Agreement applications must be submitted in Form No. 3CED with the requisite fee computed on the likely transaction value, proof of electronic payment to the designated government APA account, and supporting materials including representative authorizations, multinational structure diagrams, and detailed functional analysis; unilateral applications are filed to the Director General (International Taxation) and bilateral/multilateral applications to the Competent Authority of India, with mandatory pre filing consultation and differing filing deadlines for continuing versus prospective transactions.
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Provisions expressly mentioned in the judgment/order text.
Advance Pricing Agreement applications must be submitted in Form No. 3CED with the requisite fee computed on the likely transaction value, proof of electronic payment to the designated government APA account, and supporting materials including representative authorizations, multinational structure diagrams, and detailed functional analysis; unilateral applications are filed to the Director General (International Taxation) and bilateral/multilateral applications to the Competent Authority of India, with mandatory pre filing consultation and differing filing deadlines for continuing versus prospective transactions.
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