https://www.taxtmi.com/circulars?id=53514 Clarifications define eligibility and procedure for rollback under the APA scheme: returns under section 139(5) qualify but 139(4) returns do not; rollback applies only where the rollback-year transaction is the same in nature and counterparties as that covered by the APA and FAR does not materially differ; applicants must apply for all years in the block unless the transaction did not exist or disqualification exists; final ITAT disposal or concluded MAP for a year precludes rollback for that transaction/year; ALP may vary across years though the manner of determination must remain the same; failure by the applicant to comply with rollback procedural requirements results in cancellation of the entire agreement. en-us Wed, 10 Jun 2015 00:00:00 +0530 Fri, 12 Jun 2015 11:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=53514 Clarifications define eligibility and procedure for rollback under the APA scheme: returns under section 139(5) qualify but 139(4) returns do not; rollback applies only where the rollback-year transaction is the same in nature and counterparties as that covered by the APA and FAR does not materially differ; applicants must apply for all years in the block unless the transaction did not exist or disqualification exists; final ITAT disposal or concluded MAP for a year precludes rollback for that transaction/year; ALP may vary across years though the manner of determination must remain the same; failure by the applicant to comply with rollback procedural requirements results in cancellation of the entire agreement. Circulars Income Tax Wed, 10 Jun 2015 00:00:00 +0530 https://www.taxtmi.com/circulars?id=53514