CBDT Notifies Rollback Provision in APA
IN para 204 of his 2014 Budget Speech, the Finance Minister Mr. Jaitley said,
An Advance Pricing Agreement (APA) scheme was introduced in the year 2012. It has received good response. I propose to strengthen the administrative set up of APA to expedite disposal of applications. Further, I propose to introduce a “Roll Back” provision in the APA scheme so that an APA entered into for future transactions may also be applied to international transactions undertaken in previous four years in specified circumstances.
"Rollback year" is defined as any previous year, falling within the period not exceeding four previous years, preceding the first of the previous years.
The rollback provision stipulates that the agreement may provide for determining the arm's length price or specify the manner in which arm's length price shall be determined in relation to the international transaction entered into by the person during the rollback year.
Maybe an exercise in 'ease of doing business in India' - at least some certainty in taxation.
CBDT Notification No. 23/2015,Dated: March 14 2015