Roll back in apa scheme

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CA. Roopali Kadam

CA. Roopali Kadam (Querist)
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06 September 2015 can anyone explain Roll back in APA Scheme in simple language Exactly what is it?

CA. Roopali Kadam

CA. Roopali Kadam (Querist)
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24 October 2015 can anyone explain my above query

Aashok Kumar Sharma online

Aashok Kumar Sharma online

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22 July 2025 Sure! Here’s a simple explanation of “Roll Back” in the APA (Advance Pricing Agreement) Scheme:

What is Roll Back in APA?
Roll Back is a facility under the APA scheme that allows the taxpayer to apply the agreed transfer pricing method to past years (prior to the APA period), usually up to 4 years before the APA application year.

This means if you get an APA approved for, say, FY 2015-16 to FY 2017-18, you can also apply the same pricing method to the previous 4 years (FY 2011-12 to FY 2014-15).

Why is Roll Back useful?
It helps avoid transfer pricing disputes and litigation for those past years because the tax authorities agree to accept the APA pricing method retrospectively.

This results in certainty and stability on transfer pricing issues for those years too.

Important points:
Roll back is optional and needs to be requested by the taxpayer in the APA application.

The tax authorities may or may not agree to roll back for past years, and it is generally subject to conditions.

Roll back benefits only if the past years are under assessment or reassessment; otherwise, it may not be applicable.

In simple terms:
Roll Back means applying the “transfer pricing rules agreed today” to past years, so you don’t get taxed differently or face penalties for those years.

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