IT - Rollback Provisions of Advance Pricing Agreement Scheme - CBDT Clarifies
THE Finance Act, 2012, introduced the Advance Pricing Agreement provisions in 2012 through insertion of sections 92CC and 92CD in the Income-tax Act, 1961. Subsequently, the Advance Pricing Agreement Scheme was notified inserting Rules 10F to 10T and Rule 44GA in the Income-tax Rules, 1962.
Rollback provisions in the APA Scheme were introduced through sub-section (9A) inserted in section 92CC by the Finance (No. 2) Act, 2014 and the relevant rules, namely, Rules 10MA and 10RA, have been notified recently. Subsequent to the notification of the rules, requests for clarification regarding certain issues have been received in the Central Board of Direct Taxes.
In order to clarify such issues, the Board has adopted a Question and Answer format and the clarifications are issued for 14 questions.
CBDT Circular No.10/2015., Dated: June 10, 2015