Advance Pricing Agreements (APAs) under transfer pricing regulations in India

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An APA is an agreement between the board and taxpayer/ any person for determining ALP for specifying the manner of determining ALP in relation to international transactions. Section 92CC of The Income Tax Act, 1961 enables the board to enter into APA with any person for determining ALP or manner of determining ALP in relation to international transactions. However, the APA mechanism is not available for specified domestic transactions.