Advanced Pricing Agreement (APA) Roll Back Provisions
– By CA Puja Borar
The CBDT announced Income-tax (Third Amendment) Rules, 2015 to prescribe the conditions, procedure and manner for such roll back mechanism, namely, Rules 10MA and 10RA, vide S.O. 758(E) dated 14th March, 2015. Subsequent to the notification of the rules, requests for clarification regarding certain issues have been received in the CBDT. The CBDT therefore issued FAQs vide Circular No. 10/2015 dated 10th June, 2015, clarifying certain issues.The salient features of the rules and the clarifications have been discussed herein.