Advance Pricing Agreement programme provides pre agreed transfer pricing methods and rollback relief for multinational transactions. India's APA programme provides a pre emptive mechanism to determine the Arm's Length Price for international related party transactions for up to five years, with rules (10F-10T) governing application, processing, annual compliance reporting, audits and renewal. Rollback provisions extend certainty for up to four prior years (yielding a potential nine year period). The scheme allows unilateral, bilateral and multilateral APAs; bilateral APAs require Competent Authority negotiations and subsequent domestic agreements. Dedicated APA teams and the CBDT's Foreign Tax & Tax Research divisions process and approve APA positions, and the 2018 19 report highlights rising bilateral filings, program statistics and operational resource challenges.