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DTAA - Support services being of nature of routine administrative & business-support services, fall within definition of royalty under relevant DTAAs: ITAT (See Breaking News) TP - Certain companies merit being dropped as comparables where their activities are functionally different from those of the assessee : ITAT (See Breaking News) TP - LIBOR rate plus 300 bps should be applied for benchmarking interest on loans to subsidiaries repayable in foreign currency: ITAT (See Breaking News) TP - High-end KPO services involving specialized domain expertise such as engineering design and data analytics are not comparable to low-end BPO services such as payroll and accounts reconciliation: ITAT (See Breaking News) INTL - Although outstanding receivables from an AE constitute a separate international transaction amenable to benchmarking, determination of ALP has to depend upon the facts and circumstances of each case: ITAT (See Breaking News) TP - An APA concluded by CBDT, though not directly applicable to earlier AY, has significant persuasive value where nature of international transactions & FAR profile remain comparable: ITAT (See Breaking News) INTL - Penalties u/s 271AA & 271G not valid where AO failed to point out any specific missing documents & where TPO already accepted transactions at arm's length after verification: ITAT (See Breaking News) TP - Huge turnover or profit cannot serve as sole basis for exclusion of comparable if company is otherwise functionally comparable under Rule 10B(2): ITAT (See Breaking News) TP - Once tested party's margins are found to be at arm's length under TNMM, and adequate working capital adjustment is made, no separate adjustment on account of notional interest on delayed receivables from AEs is warranted: ITAT (See Breaking News) TP - For benchmarking interest on External Commercial Borrowing obtained from Associated Enterprise, CUP method is most appropriate method, as price of lending transaction can be directly compared with comparable uncontrolled loans: ITAT (See Breaking News) TP - AMP and R&T expenses do not constitute 'international transactions' u/s 92B in absence of agreement to provide services to AEs: ITAT (See Breaking News) DTAA - Receipts received by Hong Kong tax-resident assessee for providing managed, systems integration and hi-tech transactional services to Standard Chartered Bank through its Indian group company, not taxable in India as royalty or FTS: ITAT (See Breaking News)
 
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CBDT makes record; inks 174 APAs in current fiscal
By TII News Service
Mar 31, 2025 , New Delhi

    
THE Central Board of Direct Taxes (CBDT) entered into a record 174 Advance Pricing Agreements (APAs) with Indian taxpayers in FY 2024-25. These includes Unilateral APAs (UAPAs), Bilateral APAs (BAPAs) and Multilateral APAs (MAPAs). With this, the total number of APAs since the inception of the programme has reached 815, comprising 615 UAPAs, 199 BAPAs and 1 MAPA.

This marks the highest number of APAs signed in a single financial year since the programme’s launch. Of the 174 APAs signed, 65 were BAPAs, the highest number of BAPAs finalized in any year so far. These were a result of Mutual Agreements with India’s treaty partners, including Australia, Japan, South Korea, The Netherlands, New Zealand, Singapore, the UK, and the US.

CBDT has maintained a consistent pace in concluding APAs, having signed 125 in FY 2023-24 and 95 in FY 2022-23. Notably, this year also saw the signing of India’s first-ever MAPA. Additionally, on 27th March, 2025 a record 34 APAs were signed on a single day.

The APA Scheme aims to provide certainty to taxpayers in the area of transfer pricing by specifying pricing methods and determining the arm’s length price of international transactions in advance for up to five years. BAPAs offer the added benefit of protection against potential or actual double taxation.

The APA programme has significantly contributed to the Government of India’s mission to enhance ease of doing business, particularly for multinational enterprises engaged in extensive cross-border transactions. CBDT recognizes the collaborative spirit of taxpayers and values their role as key stakeholders in the successful implementation of the APA programme.

 
 
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