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CBDT extends time for filing roll-back applications under Advance Pricing Agreement
April, 01st 2015

The Central Board of Direct Taxes has extended the window for filing roll-back applications under the Advance Pricing Agreement relating to transfer pricing cases by three months to June 30.

The time period for filing roll-back applications under APA from March 31 to June 30 was extended by the Central Board of Direct Taxes (CBDT) in view of representations received from the industry, a released said.

Henceforth, in cases where an agreement has been entered into before March 31, the application for roll-back in prescribed form along with proof of payment of additional fee can be filed at any time on or before June 30.

"The formal notification in this regard would follow shortly," CBDT said.

With a view to reducing litigations related to transfer pricing, the CBDT came out with the 'roll-back' provision under the APA to enable companies to enter into agreements with tax authorities for the previous four years.

Under the APA, introduced in 2012, companies could enter into an agreement with tax authorities for the next five years. Now, with the roll-back norms notified they can enter into such pacts for the previous four years as well.

In his Budget speech in July 2014, Finance Minister Arun Jaitley had announced the introduction of roll-back provision in the APA scheme so that such an agreement entered into for future transactions may also be applied to international transactions undertaken in the previous four years.

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