Saurabh Maheshwari
(B.com,ACA)
(5923 Points)
Replied 07 October 2015
Hi Neha,
Roll back provisions means that the Advance pricing agreement(APA) entered can be adopted as basis for arriving transfer pricing in repsect of previous 4 Assessment Years.
(#An APA is an agreement b/w taxpayer and department prescribing the method of determining transfer price for the taxpayer's international transactions.)
For Eg. Wipro Ltd. entered into APA for a period of 3 years (AY 16-17 to AY 18-19) , in that case the method of arriving transfer price in this APA can be applied to last 4 AYs in arriving transfer price.
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