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Income Tax : In the instant case, ITAT allows the assessee to withdrawn the appeal filed for challenging the transfer pricing adjustment due to...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...
Central Board of Direct Taxes signs three more Advance Pricing Agreements pertaining to the Engineering Goods and Shipping sectors. With this, the total number of APAs entered into by the CBDT reaches 120. The Central Board of Direct Taxes (CBDT) has started the year 2017 by entering into three unilateral Advance Pricing Agreements (APAs) today. […]
International transactions covered in these Advance Pricing agreements include Software Development Services, IT enabled Services, Manufacturing ,Business Support Services.
CBDT Signs Four Unilateral Advance Pricing Agreements pertaining to various sectors of the economy including pharmaceuticals, Information Technology and Construction.
India and UK Sign three Bilateral Advance Pricing Agreements (B- APAs) taking the total number of APAs signed [both- bilateral and unilateral] to 111
CBDT signs 5 Unilateral Advance Pricing Agreements (APAs) with Indian taxpayers covering a range of international transactions, including sale of finished goods, purchase of raw materials, software development services, IT enabled services, exports and interest payment.
The Central Board of Direct Taxes (CBDT) entered into five (5) unilateral Advance Pricing Agreements (APAs) today, i.e., 23rd September, 2016, with Indian taxpayers. One of these Agreements has a rollback provision in it. With these signings, the total number of APAs entered into by the CBDT has reached 103.
The Central Board of Direct Taxes (CBDT) entered into twenty (20) Unilateral Advance Pricing Agreements (APAs) yesterday and today, i.e., 29th August, 2016 and 30th August, 2016, with Indian taxpayers. Many of these agreements also have a Rollback provision in them.
The Central Board of Direct Taxes (CBDT) entered into a Bilateral Advance Pricing Agreement (APA) on 2nd August, 2016 with the Indian subsidiary of a Japanese trading company. This is the first Bilateral Advance Pricing agreement with a Japanese company having a Rollback provision in it. Overall, it is fourth bilateral APA signed by CBDT.
Grant Thornton India has successfully assisted one of its clients in the IT sector in inking their first unilateral Advanced Pricing Agreement (APA) with the Indian Revenue within two years of filing the application in 2014. This is a milestone achievement for Grant Thornton as the APA scheme is still in its nascent stage in India.
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 corporate guarantees, royalty, software development services, IT enabled services and trading.
