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of <h1>Advance Pricing Agreement Rollback Provisions Explained: Section 92CC(9A) and Rule 10MA Conditions and Requirements</h1> The Advance Pricing Agreement (APA) scheme under Section 92CC(9A) and Rule 10MA allows for rollback provisions, which determine the arm's length price for international transactions up to four years prior to the first year of the APA's application. Conditions for rollback include the same transaction being covered, timely filing of income returns, submission of transaction reports, and application in Form 3CEDA. Rollback is not applicable if the transaction's arm's length price was appealed or if it affects income or loss declarations. The manner of determining arm's length price must be consistent across rollback and other years. Applications for rollback must include an additional fee and meet specified deadlines.
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