NCLAT: Can’t Set Aside Liquidation Order u/s 33 IBC When 3rd Party has Taken Possession of Property  ||  NCLAT: Unless Amendment Application Filed, Authority Can’t Suo Motu Amend Date of Default  ||  Delhi HC Directs Removal of 'Kindpan' Trademark in Petition Filed by ‘Mankind’  ||  J&K HC: Limitation for Challenging Award Starts after Signed Copy is Received by Party  ||  Delhi HC: ‘High Speed’ Not Sufficient to Conclude Driver Acted in Rash and Negligent Manner  ||  Allahabad HC: Huge Difference between Executing a Particular Document and Being a Witness  ||  Kerala HC: Can’t Consider Co-Opted Members of Bar Council as Separate Class from Elected Members  ||  J&K HC: Govt. Failing to Communicate Rejection of Detenue’s Representation in Time Vitiates Order  ||  SC: Electricity Act Empowers State Commissions to Regulate Open Access Within their Respective States  ||  SC: Limitation Begins from Date of Registration of Sale Deed that Constitutes Constructive Notice    

CBDT signs record number of 125 Advance Pricing Agreements (APAs) in FY 2023-2024 - (16 Apr 2024)

Direct Taxation

The Central Board of Direct Taxes (CBDT) has entered into a record 125 Advance Pricing Agreements (APAs) in FY 2023-2024 with Indian taxpayers. This includes 86 Unilateral APAs (UAPAs) and 39 Bilateral APAs (BAPAs). This marks the highest ever APA signings in any financial year since the launch of the APA programme. The number of APAs signed in FY 2023-2024 also represents a 31% increase compared to the 95 APAs signed during the preceding financial year. With this, the total number of APAs since inception of the APA programme has gone up to 641, comprising 506 UAPAs and 135 BAPAs.

The APA programme has contributed significantly to the Government of India’s mission of promoting ease of doing business, especially for Multi National Enterprises which have a large number of cross-border transactions within their group entities.During FY 2023-2024 CBDT also signed the maximum number of BAPAs in any financial year till date. The BAPAs were signed as a consequence of entering into Mutual Agreements with India’s treaty partners namely Australia, Canada, Denmark, Japan, Singapore, the UK and the US.

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 a maximum of five future years. Further, the taxpayer has the option to rollback the APA for four preceding years, as a result of which, tax certainty is provided for nine years. The signing of bilateral APAs additionally provides the taxpayers with protection from any anticipated or actual double taxation.

Tags : APA   SIGNING OF   TRANSFER PRICING  

Share :        

Disclaimer | Copyright 2025 - All Rights Reserved