AI OCR 
TaxTMI 
TaxTMI 
TaxTMI 
Provisions for Roll Back in APA Scheme [ Section 92CC(9A) read with rule 10MA ]
X X X X Extracts X X X X
X X X X Extracts X X X X
....rm's length price or specify the manner in which the arm's length price shall be determined in relation to the international transaction entered into by the person; * (b) income referred to in section 9(1)(i), or specifying the manner in which the said income is to be determined, as is reasonably attributable to the operations carried out in India by or on behalf of that person, being a non-resi....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... previous years referred to in section 92CC(4). [ Rule 10F(ha) ] * Rollback of the agreement [ Rule 10MA ] * Subject to the provisions of this rule, the agreement may provide for determining the arm's length price or specify the manner in which arm's length price shall be determined in relation to the international transaction entered into by the person during the rollback year (hereinafte....
X X X X Extracts X X X X
X X X X Extracts X X X X
....been requested by the applicant for all the rollback years in which the said international transaction has been undertaken by the applicant; and * (v) the applicant has made an application seeking rollback in Form 3CEDA in accordance with rule 10MA(5); * Non-applicability of Rollback provision [ Rule 10MA(3) ] * Rollback provision shall not be provided in respect of an international tr....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ction undertaken in any rollback year then such manner shall be the same as the manner which has been agreed to be provided for determination of arm's length price of the same international transaction to be undertaken in any previous year to which the agreement applies, not being a rollback year. * Time Limit for filling application for rollback provision [ Rule 10MA(5) ] * The applicant ....