Advance Pricing Agreement cancellation requires opportunity to be heard and a written order stating reasons and effective date. An Advance Pricing Agreement may be cancelled for failure to comply with its terms, late or materially erroneous annual compliance reports, or under related rules; the Board must give the assessee an opportunity to be heard and, for bilateral or multilateral APAs, the competent authority must communicate reasons to counterpart authorities. Cancellation orders must be written, state reasons and reasons for non-acceptance of the assessee's submissions, specify the effective date where applicable, and declarations of voidness for fraud or misrepresentation must likewise be written with reasons. The order must be intimated to the Assessing Officer and the Transfer Pricing Officer.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Advance Pricing Agreement cancellation requires opportunity to be heard and a written order stating reasons and effective date.
An Advance Pricing Agreement may be cancelled for failure to comply with its terms, late or materially erroneous annual compliance reports, or under related rules; the Board must give the assessee an opportunity to be heard and, for bilateral or multilateral APAs, the competent authority must communicate reasons to counterpart authorities. Cancellation orders must be written, state reasons and reasons for non-acceptance of the assessee's submissions, specify the effective date where applicable, and declarations of voidness for fraud or misrepresentation must likewise be written with reasons. The order must be intimated to the Assessing Officer and the Transfer Pricing Officer.
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