An APA is a agreement between a taxpayer and at least one tax authority concerning the TP method functional to a taxpayer’s inter-company transactions and will usually cover multiple years.
Income Tax : Form 54 streamlines APA renewals for similar transactions, enabling quicker evaluation and resolution. This enhances administrativ...
Income Tax : Form 52 replaces Form 3CEF and mandates annual APA compliance reporting. It introduces structured disclosures and ensures accurate...
Income Tax : Once submitted, Form 51 cannot be modified except for defect corrections. Taxpayers must ensure accuracy at the time of filing. Th...
Income Tax : Critical assumptions define the conditions under which APA pricing remains valid and reliable. The key takeaway is that any materi...
Income Tax : The amendment permits associated enterprises affected by an APA to file or modify returns. This enables proper tax adjustment and ...
Income Tax : CBDT signed a record number of APAs to provide clarity on transfer pricing and reduce disputes. The framework ensures advance dete...
Income Tax : CBDT’s 2024-25 APA report details 174 new agreements, including record bilateral deals, advancing tax certainty and reducing cro...
Corporate Law : CBDT signed 174 Advance Pricing Agreements in FY 2024-25, including a record number of bilateral agreements, to improve transfer p...
Income Tax : Insights from India's APA Programme Annual Report 2023-24, highlighting tax certainty, record signings, and benefits for multinati...
Income Tax : CBDT achieves a record 125 APAs in FY 2023-24, marking a 31% increase. Learn about the significance and impact on transfer pricing...
Income Tax : The issue was whether the Assessing Officer could alter income despite a valid APA and modified return. The Court held that withou...
Income Tax : ITAT Delhi held that Transfer Pricing Adjustment in respect of transaction of payment of royalty is set aside and Transfer Pricing...
Income Tax : ITAT held that advance pricing agreement APA is applicable only for specified time span not exceeding five consecutive previous ye...
Income Tax : In the instant case, ITAT allows the assessee to withdrawn the appeal filed for challenging the transfer pricing adjustment due to...
Income Tax : CBDT has entered into 26 APAs in the first 5 months of the current financial year (April to August, 2019). With the signing of the...
Income Tax : 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, ...
Income Tax : Central Board of Direct Taxes signed 11 unilateral APAs on 28th March, 2016. With this signing, India has entered into 59 bilatera...
Income Tax : CIRCULAR NO. 10/2015 The Advance Pricing Agreement provisions were introduced in 2012 through insertion of sections 92CC and 92CD ...
Income Tax : Notification No. 23/2015 - Income Tax In exercise of the powers conferred by sub-sections (9) and(9A) of section 92CC read with s...
The Central Board of Direct Taxes (CBDT) entered into seven more Advance Pricing Agreements (APAs) during the month of February, 2018. All the seven are Unilateral APAs. With the signing of these Agreements, CBDT has crossed an important milestone of having signed 200 APAs. The total number of APAs entered into by the CBDT till […]
The Central Board of Direct Taxes (CBDT) has entered into five Unilateral Advance Pricing Agreements (UAPA) and two Bilateral Advance Pricing Agreements (BAPA) during the month of January, 2018.
The CBDT introduced the rollback rules under the APA program on 14 March 2015. There were some ambiguities about the implementation of the rollback rules, and therefore, CBDT issued Frequently Asked Questions (FAQs) clarifying certain issues.
CBDT has entered into three more Advance Pricing Agreements (APAs) during the month of December, 2017. While two of the Agreements are Unilateral, one is a Bilateral with the United Kingdom. With the signing of these Agreements, the total number of APAs entered into by the CBDT has gone up to 189. This includes 173 Unilateral APAs and 16 Bilateral APAs.
CBDT has entered into 2 Bilateral Advance Pricing Agreements (APAs) during the month of November, 2017. These Agreements are the first ever Bilateral APAs with The Netherlands. With the signing of these Agreements, the total number of APAs entered into by the CBDT has gone up to 186. This includes 171 Unilateral APAs and 15 Bilateral APAs.
The Central Board of Direct Taxes (CBDT) has entered into 7 more Advance Pricing Agreements (APAs) during the month of October, 2017. All these Agreements are Unilateral.
The Central Board of Direct Taxes (CBDT) has entered into 2 Unilateral Advance Pricing Agreements (UAPAs) with Indian Taxpayers during September, 2017. With the signing of these 2 Agreements, the total number of APAs entered into by CBDT till date has reached 177. This includes 164 Unilateral APAs and 13 Bilateral APAs. In the current financial year, a total of 25 APAs (2 Bilateral and 23 Unilateral) have been signed till date.
CBDT has entered into 4 more Advance Pricing Agreements (APAs) during August, 2017. Out of these 4 Agreements, 3 are Unilateral and 1 is a Bilateral. The Bilateral APA is for international transactions between an Indian company and a UK-based company.
Central Board of Direct Taxes (CBDT) entered into nine Unilateral Advance Pricing Agreements (UAPAs) with Indian taxpayers in the month of July, 2017. Some of the UAPAs signed had rollback provisions also.
The CBDT, with Central Government’s approval, enter into APA with the applicant assesse determining the ALP and/or methods for determining ALP which is to be followed notwithstanding anything contained in section 92C / 92CA of the Act
