Roll back of Agreement

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....red to as the rollback provision). (2) The rollback provision shall be subject to the following:- (a) the international transaction is same as the international transaction to which the agreement (other than the rollback provision) applies; (b) the return of income for the relevant rollback year has been or is furnished by the applicant within the time specified in section 263....

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....of an appeal before the Appellate Tribunal and the Appellate Tribunal has passed an order disposing of such appeal at any time before signing of the agreement; or (b) the application of rollback provision has the effect of reducing the total income or increasing the loss, as the case may be, of the applicant as declared in the return of income of the said year. (4) Where the rollback p....