Income Tax

CBDT signed two Unilateral APA with Indian taxpayers related to chip design software and IT software

CBDT signed two Unilateral APA with Indian taxpayers related to chip design/development of embedded software and IT software development sectors 

Central Board of Direct Taxes (CBDT) signs 2 Unilateral Advance Pricing Agreements (APA) with Indian taxpayers taking the number of APAs signed in the current Financial Year to four

The progress of the APA Scheme strengthens the Government’s commitment to foster a non-adversarial tax regime

The Central Board of Direct Taxes (CBDT) has entered into two Unilateral Advance Pricing Agreements (APA) on 04th May, 2017 and 11th May, 2017 respectively, with Indian taxpayers. One of the Agreements also has “Rollback” provision.

The two APAs signed pertain to chip design/development of embedded software and Information technology (software development) sectors of the economy. The number of APAs signed in the current financial year now is four. The CBDT expects more APAs to be signed in the near future. The progress of the APA Scheme strengthens the Government’s commitment to foster a non-adversarial tax regime.

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 roll-back the APA for four preceding years, as a result of which, total nine years of tax certainty is provided. Since its inception, the APA scheme has attracted tremendous interest among Multi National Enterprises (MNEs).

****
Share

Recent Posts

  • Income Tax

Form 26 to replace Form 3CD of tax audit report by a CA from Tax Year 2026-27

Form 26 to replace Form 3CD of tax audit report from Tax Year 2026-27 Draft Form 26 has been issued…

5 hours ago
  • Income Tax

When no addition is made on the basis of reasons recorded, reopening is bad in law

When AO do not make any addition on the basis of the reasons on which the reopening was done, the…

6 hours ago
  • Insurance

No separate compensation for loss of love and affection under MV Act – SC

Under MV Act separate compensation can not be granted under the head “loss of love and affection” – Supreme Court…

1 day ago
  • Income Tax

Trust accredited by National Open School eligible for registration u/s 12AB & u/s 80G

Trust accredited by National Institute of Open Schooling eligible for registration u/s.12AB and u/s 80G of the Act. In a…

1 day ago
  • Income Tax

Delay in furnishing Form 10B – Covid Period to be excluded as per decision of Supreme Court

Delay in furnishing Form 10B – Period between 15.03.2020 till 20.08.2022 to be excluded as per decision of Hon'ble Supreme…

3 days ago
  • Income Tax

Section 271AAB does not grant any immunity from penalty in terms of section 273B

Section 271AAB does not grant any immunity from penalty even if the assessee was able to show some reasonable cause…

3 days ago