Friday , September 11, 2026 |   07:31:11 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Newsletters
 
NEWS FLASH
 
Private investment ups in space economy but Govts remain central to innovation: OECD (See Brief) TP - Assessment order is complete only on being digitally signed - order is barred by limitation where date borne on order or date on which AO completed underlying process, is not decisive: ITAT (See Breaking News) TP - Characterization of entity for transfer pricing purposes must be based on detailed FAR analysis: ITAT (See Breaking News) DTAA - Corporate charges paid for intra-group managerial, administrative, marketing & business support services & not making available any technical knowledge, cannot be treated as Fees for technical services: ITAT (See Breaking News) I-T - Reimbursements of salary for seconded employees made on cost-to-cost basis without income element are not taxable in hands of foreign recipient: ITAT (See Breaking News) TP - In absence of agreement, arrangement, or understanding between assessee & its AE to share or incur AMP expenses for sole benefit of AE, domestic AMP spending cannot be characterized as international transaction u/s 92B: ITAT (See Breaking News) TP - No notional interest can be imputed on trade receivables if assessee is debt-free entity: ITAT (See Breaking News) TP - While an APA is not strictly binding on AYs outside its formal coverage, pricing methodology & agreed margins have strong persuasive value, if functional, asset & risk profiles & nature of international transactions are same: ITAT (See Breaking News) I-T - Regulatory evidence from bank and RBI confirming identity theft and fraudulent account opening overrides any presumptions arising solely from SFT data: ITAT (See Breaking News) I-T - Expatriate salary for employees working exclusively in India is not head office expenditure u/s 44C: ITAT (See Breaking News) TP - TPO's approach of comparing inter-unit transfers of semi-finished goods with third-party sales of finished goods, while ignoring variations in product mix & market dynamic, is invalid: ITAT (See Breaking News) TP - TPO's approach of comparing inter-unit transfers of semi-finished goods with third-party sales of finished goods, while ignoring variations in product mix & market dynamic, is invalid: ITAT (See Breaking News) TP - Once the genuineness of scientific research expenditure is undisputed, any amount not certified for weighted deduction must be allowed as a normal deduction u/s 35(1)(iv): ITAT (See Breaking News) I-T - Merely because broken-period amount was received from the purchaser of the NCDs, instead of the issuer, its character would not change from interest to capital gains : ITAT (See Breaking News) I-T - Separate adjustment was warranted merely because no interest was charged to non-AEs where assessee had not furnished sufficient details or evidence to substantiate the claim : ITAT (See Breaking News) I-T - Interest from third-party overseas banks is only taxable if debt is used for business carried on in India, otherwise it falls outside scope of Sec 9(1)(v)(c): ITAT (See Breaking News) TP - TPO not justified in determining value of management services at nil using CUP method when assessee establishes actual rendition of services through supporting evidence: ITAT (See Breaking News) TP - ALP for particular transaction cannot be determined as nil merely because assessee had not established immediate or quantifiable benefit from each individual service: ITAT (See Breaking News) TP - TPO cannot assume the place of a businessperson so as to question commercial expediency of any transaction or the need to avail services from an AE: ITAT (See Breaking News)
 
TII SEARCH
 
 
   
Home >> News Brief
 

CBDT entered into 62 APAs in last fiscal
By TII News Service
Apr 01, 2022 , New Delhi

    

THE Central Board of Direct Taxes (CBDT) has entered into 62 Advance Pricing Agreements (APA) in FY 2021-22 with Indian taxpayers. This includes 13 Bilateral APAs (consequent to Mutual Agreement between India and its treaty partners) and 49 Unilateral APAs. With this, the total number of APAs since inception of the APA program has gone up to 421.

Despite severe economic and social disruption caused by the CoVID-19 pandemic in first part of the financial year, the number of APAs signed compares very well with the APAs signed in the preceding two years (31 APAs in FY 2020-21 and 57 APAs in FY 2019-20).

The APA Scheme endeavours to provide certainty to taxpayers in the domain of transfer pricing by specifying the methods of pricing and determining the arm's length price of international transactions in advance for the maximum of five future years. Further, the taxpayer has the option to rollback the APA for four preceding years, as a result of which, total nine years of tax certainty is provided.

The progress of the APA scheme strengthens the Government's resolve of fostering a non-adversarial tax regime and increasing the ease of doing business in India. CBDT appreciates the cooperative and transparent attitude of taxpayers in this regard.

 
 
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.