(1)The Board, with the approval of the Central Government, may enter into an advance pricing agreement with any person, determining the—(a)arm's length price or specifying the manner in which the arm's length price is to be determined, in relation to an international transaction to be entered into by that person;(b)income referred to in section 9(2), or specifying the manner in which the said income is to be determined, as is reasonably attributable to the operations carried out in India by or on behalf of that person, being a non-resident.