Advance Pricing Agreement requires modified returns and assessment actions, suspending TPO/DRP audit for covered transactions.

Entry into an Advance Pricing Agreement requires the taxpayer to file a modified return limited to the APA for covered years; that return is deemed a valid return and the assessing officer must complete or, if necessary, reassess income for those years in accordance with the APA. Transactions not covered by the APA are unaffected. If a TPO reference or DRP proceeding is pending for a covered transaction, the assessing officer must notify them and the TPO/DRP must suspend further audit or directions; related appeals and objections are to be withdrawn.

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