Revision of Advance Pricing Agreement: procedure for revising APAs, reassessment, and filing modified returns following revision. Revision of Advance Pricing Agreement (APA) under Rule 10Q allows the Board to revise an APA for changed critical assumptions, unmet conditions, qualifying changes in law, or on competent authority request. Revision may be suo motu or on request; except when requested by the assessee, revision requires an opportunity to be heard and the assessee's agreement, failing which cancellation under Rule 10R may follow. The revised APA must specify original and revised application dates. After revision the assessee must file a modified return within three months and the assessing officer will reassess income for relevant assessment years per the revised APA.
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Provisions expressly mentioned in the judgment/order text.
Revision of Advance Pricing Agreement: procedure for revising APAs, reassessment, and filing modified returns following revision.
Revision of Advance Pricing Agreement (APA) under Rule 10Q allows the Board to revise an APA for changed critical assumptions, unmet conditions, qualifying changes in law, or on competent authority request. Revision may be suo motu or on request; except when requested by the assessee, revision requires an opportunity to be heard and the assessee's agreement, failing which cancellation under Rule 10R may follow. The revised APA must specify original and revised application dates. After revision the assessee must file a modified return within three months and the assessing officer will reassess income for relevant assessment years per the revised APA.
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