Provision for roll back in apa scheme

This query is : Resolved

Guest

Guest (Querist)

07 October 2015 Dear Experts If someone can please explain with examples the provision for Roll back in Advance pricing agreement scheme u/s 92CC? Thank you.

ANKIT AGARWAL

ANKIT AGARWAL (Expert)
Follow

08 October 2015 Transfer Pricing Assessments (Before TPO) is currently in progress for AY 2012-13 which will get time barred in January 2016. Hence if you have made an application for a APA Application on 1st April 2015 and you receive a APA Agreement today, it will get applicable for AY 2016-17 to 2021-22 along with rollback years i.e AY 2012-13 to AY 2015-16. Hence you can take shield of the APA in the current Assessment Proceedings relevant for the AY 2012-13 as well. The rollback Provisions were announced by Shri Arun Jaitley last year in his Maiden Budget.