Income-tax (Tenth Amendment) rules, 2012 - Insertion of Rules 10F, 10G, 10H, 10-I, 10-J, 10K, 10L, 10M, 10N, 10-O, 10P, 10Q, 10R, 10S, 10T & 44GA - 36/2012 - Income Tax

Advance Pricing Agreement scheme clarifies eligibility, application, processing, compliance audits and revision mechanisms for transfer pricing.

The Income-tax Rules introduce an Advance Pricing Agreement (APA) Scheme defining eligibility for taxpayers with international transactions, mandating pre-filing consultation and prescribing Forms 3CEC and 3CED for pre-filing and APA applications. The procedure sets a fee schedule, completeness checks with deficiency cure periods, team-led processing including meetings, information calls and site visits, and distinct handling for unilateral, bilateral and multilateral APAs via the competent authority. APAs may specify covered transactions, agreed transfer pricing methodology, arm's length outcomes and critical assumptions, and include mechanisms for annual compliance reporting, compliance audits, revision and cancellation where assumptions change or non-compliance is found.