Advance Pricing Agreement

How does Advance Pricing Agreement help dispute resolution?

Income Tax - The Advance Pricing Agreement program has been a key dispute prevention mechanism in the Indian direct taxes set-up. There are three kinds of Advance Pricing Agreements – unilateral, bilateral and multilateral. Credibility of a tax administration depends to a large extent upon the efficacy of its dispute resolution mechanism. Advance Pr...

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Is there a need to renegotiate APAs in light of the COVID outbreak?

Income Tax - Over the last few months, we have witnessed the profound impact of the COVID-19 outbreak on our day to day lives. The outbreak has led to imposition of lockdown across the globe which in turn restricted global economic activity. Economies and markets have been hit hard by the outbreak which resulted in businesses making desperate [&hellip...

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Advance Pricing Agreements

Income Tax - Evolution of advance pricing agreement concept in India The transfer pricing framework in India has been introduced through Finance Act, 2001 which requires determination of Arm Length Price (ALP) for all the international transaction between associated enterprises. Since then, the ALP determination has been the matter of long aged and nu...

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Attribution of profit to PE in Safe Harbour Rules and in APA

Income Tax - Budget 2020:Amendment for providing attribution of profit to Permanent Establishment in Safe Harbour Rules under section 92CB and in Advance Pricing Agreement under section 92CC Section 92CB of the Act empowers the Central Board of Direct Taxes (Board) for making safe harbour rules (SHR) to which the determination of the arm’s lengt...

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Advance Pricing Agreements- International Taxation & Latest Changes

Income Tax - According to Indian Tax Laws, it is an agreement between CBDT and any person, which determines, in advance, the arm’s length price or specifies the manner of the determination of arm’s length price (or both), in relation to an international transaction. ...

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Advance Pricing Agreement (APA) -Programme of India- Annual Report (2018-19)

Income Tax - The Advance Pricing Agreement (APA) programme in India was introduced more than seven years ago. It is currently in its 7th annual cycle of examination and processing of applications. The CBDT is very happy about the fact that this programme has been accepted well by taxpayers and tax consultants. We are very proud of the results generate...

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CBDT inks the 300th Advance Pricing Agreement

Income Tax - The Central Board of Direct Taxes (CBDT) has signed the 300th Advance Pricing Agreement (APA) during the month of September, 2019. This is a significant landmark of India’s APA Programme, which is currently in its seventh year. Three APAs were entered into in September, 2019 (2 Unilateral and 1 Bilateral APA), which has taken the [&hell...

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CBDT signs 18 Advance Pricing Agreement in March, 2019

Income Tax - CBDT has entered into 18 APAs in the month of March 2019, which includes 03 Bilateral APAs (BAPAs). With the signing of these APAs, the total number of APAs entered into by the CBDT in the year 2018-19 stands at 52...

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Total APAs entered into by CBDT increases to 244

Income Tax - Total number of APAs entered into by the CBDT has gone up to 244, which includes 220 UAPAs and 24 BAPAs. It is noteworthy that one of the UAPAs signed in October is a renewal application and the same has been concluded in a time span of only 7 months....

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Annual Report on India’s Advance Pricing Agreement (APA) Programme– 2017-18

Income Tax - The Advance Pricing Agreement (APA) Programme in India is six years old now and has been heralded as a success. The CBDT is extremely proud of this Programme and its achievements. The Programme has been successful in winning the confidence of taxpayers by providing them with an alternate dispute resolution mechanism in respect of transfer...

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ITAT allows to withdrawn appeal challenging TP Adjustment due to APA

Citizen Watches (India) Pvt. Ltd. Vs. ACIT (ITAT Bangalore) - In the instant case, ITAT allows the assessee to withdrawn the appeal filed for challenging the transfer pricing adjustment due to Advance pricing agreement filed u/s 92CC of the Income tax Act....

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CBDT enters into 26APAs during current Financial Year

NA - (04/09/2019) - CBDT has entered into 26 APAs in the first 5 months of the current financial year (April to August, 2019). With the signing of these APAs, the total number of APAs entered into by the CBDT as of now stand at 297, which includes 32 BAPAs....

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CBDT revises format of Form No. 3CED- Application for Advance Pricing Agreement

Notification No. 53/2017-Income Tax [S.O. 1927(E)] - (16/06/2017) - S.O. 1927(E). In exercise of the powers conferred by section 295 read with sub-section (9) of section 92CC of the Income-tax Act, 1961 (43 of 1961), the Central Board of Direct Taxes hereby makes the following rules further to amend the Income-tax Rules, 1962, namely...

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CBDT signs 11 more unilateral Advance Pricing Agreements

NA - (29/03/2016) - Central Board of Direct Taxes signed 11 unilateral APAs on 28th March, 2016. With this signing, India has entered into 59 bilateral and/or unilateral APAs. 50 of these agreements have been signed in the current financial year. The agreements cover a range of international transactions, including cor...

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FAQs: Rollback Provisions of Advance Pricing Agreement Scheme

Circular No. 10/2015-Income Tax - (10/06/2015) - CIRCULAR NO. 10/2015 The Advance Pricing Agreement provisions were introduced in 2012 through insertion of sections 92CC and 92CD in the Income-tax Act, 1961 by the Finance Act, 2012. Subsequently, the Advance Pricing Agreement Scheme was notified vide S.O. 2005 (E), dated 30/8/2012, thereby inserti...

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Rules & forms for rollback of Advance Pricing Agreement

Notification No. 23/2015 - Income Tax - (14/03/2015) - Notification No. 23/2015 - Income Tax In exercise of the powers conferred by sub-sections (9) and(9A) of section 92CC read with section 295 of the Income-tax Act, 1961 (43 of 1961), the Central Board of Direct Taxes hereby makes the following rules further to amend the Income-tax Rules, 1962, namel...

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Recent Posts in "Advance Pricing Agreement"

ITAT allows to withdrawn appeal challenging TP Adjustment due to APA

Citizen Watches (India) Pvt. Ltd. Vs. ACIT (ITAT Bangalore)

In the instant case, ITAT allows the assessee to withdrawn the appeal filed for challenging the transfer pricing adjustment due to Advance pricing agreement filed u/s 92CC of the Income tax Act....

Read More

How does Advance Pricing Agreement help dispute resolution?

The Advance Pricing Agreement program has been a key dispute prevention mechanism in the Indian direct taxes set-up. There are three kinds of Advance Pricing Agreements – unilateral, bilateral and multilateral. Credibility of a tax administration depends to a large extent upon the efficacy of its dispute resolution mechanism. Advance Pr...

Read More
Posted Under: Income Tax |

Is there a need to renegotiate APAs in light of the COVID outbreak?

Over the last few months, we have witnessed the profound impact of the COVID-19 outbreak on our day to day lives. The outbreak has led to imposition of lockdown across the globe which in turn restricted global economic activity. Economies and markets have been hit hard by the outbreak which resulted in businesses making desperate [&hellip...

Read More
Posted Under: Income Tax |

Advance Pricing Agreements

Evolution of advance pricing agreement concept in India The transfer pricing framework in India has been introduced through Finance Act, 2001 which requires determination of Arm Length Price (ALP) for all the international transaction between associated enterprises. Since then, the ALP determination has been the matter of long aged and nu...

Read More
Posted Under: Income Tax |

Attribution of profit to PE in Safe Harbour Rules and in APA

Budget 2020:Amendment for providing attribution of profit to Permanent Establishment in Safe Harbour Rules under section 92CB and in Advance Pricing Agreement under section 92CC Section 92CB of the Act empowers the Central Board of Direct Taxes (Board) for making safe harbour rules (SHR) to which the determination of the arm’s lengt...

Read More
Posted Under: Income Tax |

Advance Pricing Agreements- International Taxation & Latest Changes

According to Indian Tax Laws, it is an agreement between CBDT and any person, which determines, in advance, the arm’s length price or specifies the manner of the determination of arm’s length price (or both), in relation to an international transaction. ...

Read More
Posted Under: Income Tax |

Advance Pricing Agreements and its Latest Developments

This article is about Advance Pricing Agreements (APA) provisions. Mainly it will cover the basic meaning of Advance Pricing Agreement, types of Advance Pricing Agreement, objectives of Advance Pricing Agreement and number of Advance Pricing Agreement signed by India. What is an Advance Pricing Agreement (APAs)? According to Indian Tax La...

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Posted Under: Income Tax |

Advance Pricing Agreement (APA) -Programme of India- Annual Report (2018-19)

The Advance Pricing Agreement (APA) programme in India was introduced more than seven years ago. It is currently in its 7th annual cycle of examination and processing of applications. The CBDT is very happy about the fact that this programme has been accepted well by taxpayers and tax consultants. We are very proud of the results generate...

Read More
Posted Under: Income Tax |

CBDT inks the 300th Advance Pricing Agreement

The Central Board of Direct Taxes (CBDT) has signed the 300th Advance Pricing Agreement (APA) during the month of September, 2019. This is a significant landmark of India’s APA Programme, which is currently in its seventh year. Three APAs were entered into in September, 2019 (2 Unilateral and 1 Bilateral APA), which has taken the [&hell...

Read More
Posted Under: Income Tax |

CBDT enters into 26APAs during current Financial Year

NA 04/09/2019

CBDT has entered into 26 APAs in the first 5 months of the current financial year (April to August, 2019). With the signing of these APAs, the total number of APAs entered into by the CBDT as of now stand at 297, which includes 32 BAPAs....

Read More

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