Thursday , June 25, 2026 |   19:12:01 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Newsletters
 
NEWS FLASH
 
TP - Value of international transaction pertaining to low end IS&T services reconciled with segment revenue, should be considered to compute margin: ITAT (See Breaking News) I-T - Penalty u/s 271(1)(c) cannot be sustained as there is no conclusive finding of concealment or furnishing of inaccurate particulars: ITAT (See Breaking News) How to woo FDI into India? (See TII SPECIAL) TP - Company merits being dropped as comparable where regulatory findings reveal financial irregularities & diversion of funds, rendering its financial results & operating margins unreliable: ITAT (See Breaking News) TP - Once the DRP directions were uploaded on ITBA portal in September 2024, then AO is required to pass final assessment order within one month from end of that month: ITAT (See Breaking News) I-T - If final assessment order is passed beyond limitation period computed under Section 144C r/w/s 153, such order is without jurisdiction: ITAT (See Breaking News) DTAA - Reimbursement does not contain any income element so as to be taxed as Fees for Technical Services either under I-T Act or under India–Japan tax treaty: ITAT (See Breaking News) DTAA - DDT u/s 115-O is tax levied on distributed profits of domestic company & not on income of shareholder; ergo does not fall within scope of DTAA benefits - YES: ITAT (See Breaking News) I-T- Final assessment order passed in violation of binding DRP directions is void ab initio: ITAT (See Breaking News) DTAA - Excess DDT paid u/s 115-O can be refunded u/s 237 even if not claimed in return due to ITR utility limitation; DTAA rate of 10% applies to DDT: ITAT (See Breaking News) I-T - Consultancy receipts cannot be taxed in India as business income in hands of non-resident in absence of evidence establishing business connection, PE, or fixed base in India: ITAT (See Breaking News) DTAA - Referral fee is purely a commercial income arising from introduction of clients & does not involve any managerial, technical or consultancy services; cannot be treated as FTS: ITAT (See Breaking News) TP - Internal CUP based on tariff charged charged by DGVCL to consumers is reliable benchmark: ITAT (See Breaking News) The 2026 Income Tax Ordinance and non-residents (See TII Edit) DTAA - Re-assessment is invalidated where commenced on incorrect assumption of facts: ITAT (See Breaking News) TP - Variations in functional profile, turnover filter and RPT filter, calls for exclusion of comparable for benchmarking purposes: 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.