Friday , November 6, 2026 |   15:49:08 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Newsletters
 
NEWS FLASH
 
TP - Uploading DRP directions on ITBA portal constitutes valid communication - mandatory one-month period u/s 144C(13) for completing assessment must be reckoned from end of month in which directions are received: ITAT (See Breaking News) I-T - Indian AE do not constitutes Dependent Agent PE of assessee in India under Article 5(5) of India-Switzerland DTAA, if AE does not habitually exercise authority to negotiate and conclude contracts on behalf of assessee: ITAT (See Breaking News) I-T - Compensation paid pursuant to out-of-court settlement is not hit by Explanation 1 to Sec 37(1): ITAT (See Breaking News) TP - Since clause (i) of section 92BA having been omitted by Finance Act, 2017 without any saving clause, any transfer pricing adjustment & reference to TPO made under the omitted clause, is non est in law: ITAT (See Breaking News) TP - LIBOR is appropriate rate of interest for benchmarking foreign currency loans advanced by assessee to its 100% subsidiaries, without any ad hoc mark-up: ITAT (See Breaking News) DTAA - In-house support involving coordination for bug-fixing, involves transfer of technology or technical know-how does not satisfy make available clause - consideration for such activity not Fees for Technical Services: ITAT (See Breaking News) I-T - Reimbursements of IT infrastructure & common software costs, salary expenses and travel expenses are of nature of cost-to-cost recharges without any profit element & do not constitute Fees for Technical Services liable to TDS u/s 195: ITAT (See Breaking News) TP - Fully & compulsorily convertible debentures remain hybrid instruments that function as debt until they are actually converted into equity shares: ITAT (See Breaking News)
 
TII SEARCH
 
 
   
Home >> News Brief
 

CBDT enters into four more APAs
By TII News Service
Feb 07, 2017 , New Delhi

    
THE Central Board of Direct Taxes (CBDT) has entered into four more unilateral Advance Pricing Agreements (APAs) on February 6, 2017.

The four APAs signed pertain to the Manufacturing, Financial and Information Technology sectors of the economy. The international transactions covered in these agreements include Contract Manufacturing, IT Enabled Services and Software Development Services.

With this, the total number of APAs entered into by the CBDT has reached 130. This includes 8 bilateral APAs and 122 Unilateral APAs. In the current financial year, a total of 66 APAs (5 bilateral APAs and 61 unilateral APAs) have already been entered into. The CBDT expects more APAs to be concluded and signed before the end of the current fiscal.

The APA Scheme was introduced in the Income-tax Act in 2012 and the “Rollback” provisions were introduced in 2014. The scheme endeavours to provide certainty to taxpayers in the domain of transfer pricing by specifying the methods of pricing and determining the prices of international transactions in advance. Since its inception, the APA scheme has evinced a lot of interest from taxpayers and that has resulted in more than 700 applications (both unilateral and bilateral) being filed so far in about five years.

The progress of the APA Scheme strengthens the Government's resolve of fostering a non-adversarial tax regime. The Indian APA program has been appreciated nationally and internationally for being able to address complex transfer pricing issues in a fair and transparent manner.

 
 
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII
  • DTAA
  • Circulars (I-T Act, 1922)
  • Limited Treaties
  • Other Treaties
  • TIEAs
  • Notifications
  • Circulars
  • Relevant Sections of I-T Rules,1962
  • Instructions
  • Administrative Orders
  • DRP Panel
  • I-T Act, 1961
  • MLI
  • Relevant Portion of I-T Act,1922
  • GAAR
  • MAP
  • OECD Conventions
  • Draft Guidelines
  • DTC Bill
  • Committee Reports
  • FATCA
  • Intl-Taxation
  • Finance Acts
  • Manual on EoI
  • UN Model Taxation
  • Miscellaneous
  • Cost Inflation Index
  • Union Budget
  • Information Security Guidelines
  • APA Annual Report
  • APA Rules
  • Miscellaneous
  • Relevant Sections of Act
  • Instructions
  • Circulars
  • Notifications
  • Draft Notifications
  • Forms
  • TP Rules
  • APA FAQ
  • UN Manual on TP
  • Safe Harbour Rules
  • US Transfer Pricing
  • FEMA Act
  • Exchange Manual
  • Fema Notifications
  • Master Circulars
  • Press Notes
  • Rules
  • FDI Circulars
  • RBI Circulars
  • Reports
  • FDI Approved
  • RBI Other Notifications
  • FIPB Review
  • FEO Act
  • INTELLECTUAL PROPERTY
  • CBR Act
  • NBFC Report
  • Black Money Act
  • PMLA Instruction
  • PMLA Bill
  • FM Budget Speeches
  • Multimodal Transportation
  • Vienna Convention
  • EXIM Bank LoC
  • Manufacturing Policy
  • FTDR Act, 1992
  • White Paper on Black Money
  • Posting Policy
  • PMLA Cases
  • Transfer of Property
  • MCA Circular
  • Limitation Act
  • Type of Visa
  • SSAs
  • EPFO
  • Acts
  • FAQs
  • Rules
  • Guidelines
  • Tourist Visa
  • Notifications
  • Arbitration
  • Model Text
  • Agreements
  • Relevant Portion of I-T Act
  • I-T Rules, 1962
  • Circulars
  • MISC
  • Notification
  • About Us
  • Contact Us
  •  
     
    A Taxindiaonline Website. Copyright © 2010-2025 | Privacy Policy | Taxindiainternational.com Pvt. Ltd. OPC All rights reserved.