Advance pricing agreement is applicable only to specified assessment years

DCIT Vs AGS Customer Services India P. Ltd. (ITAT Pune) Issue- Whether Ld. CIT(A) has erred in determining the ALP of international transaction related to Business Support Services in the light of terms and conditions of the Advance Pricing Agreement (APA) applicable to AY 2011-12 to AY 2015- 16, without appreciating that the terms and conditions set out in APA cannot be applied to the assessment year AY 2010-11 which is not a apart of APA. CIT(A)’s admittedly appears to have gone by the assessee’s “advance pricing arrangement (APA)” dated 29.08.2016 with the CBDT adopting cost + 15% m...