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        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.

        <h1>Advance Pricing Agreements provide transfer pricing certainty with rollback extending prior year coverage and non adversarial compliance.</h1> The Central Board of Direct Taxes entered into two Unilateral Advance Pricing Agreements, one with a rollback option, to provide transfer pricing certainty by specifying methods of pricing and determining the arm's length price for international transactions prospectively for up to five future years while allowing rollback to prior years, thereby fostering a non adversarial tax compliance environment for affected taxpayers.

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