years included in the book profit on account of an advance pricing agreement entered into by the assessee under section 92CC or on account
advance pricing agreement with any person, determining the arm's length price or specifying the manner in which arm's length price ... section 92CA, the aim's length price of any international transaction, in respect of which the advance pricing agreement has been entered into, shall
advance pricing agreement with any person, determining the— (a) arm's length price or specifying the manner in which the arm's length price ... price of any international transaction or the income referred to in clause (b) of sub-section (1), in respect of which the advance pricing agreement
been accepted by the assessee; (iii) is determined by an advance pricing agreement entered into by the assessee under section 92CC, on or after ... resolution of an assessment by way of the mutual agreement procedure under an agreement entered into under section 90 or section 90A for avoidance
Section 92CD in The Income Tax Act, 1961
92CD. Effect to advance pricing agreement.
(1) Notwithstanding anything to the contrary contained in section 139, where
years included in the book profit on account of an advance pricing agreement entered into by the assessee under section 92CC or on account
first principles, and that
is concerning the impact of Advance Pricing Agreement being signed by the assessee's
Indian associated enterprises, namely GIA India ... which is in accordance with the Advanced Pricing
Agreement ["APA"] dated 07 May 2018 entered into by GIA India Laboratory
Private Limited
modified return was only in respect of Transfer
Pricing adjustments giving effect to Unilateral Advance
Pricing Agreement. It is stated that it computed additional
income ... 92CA, the arm's length price of any
international transaction, in respect of which the advance
pricing agreement has been entered into, shall
Section 92CD (3) of the Act as a result of the
Advance Pricing Agreement (APA) dated 28.03.2023; and
2. That the impugned notice even otherwise ... assessee has entered into
an Advance Pricing Agreement with the Central Board of Direct Taxes after an
assessment proceedings has been completed, the requirement
Section 92CD (3) of the Act as a result of the
Advance Pricing Agreement (APA) dated 28.03.2023; and
2. That the impugned notice even otherwise ... assessee has entered into
an Advance Pricing Agreement with the Central Board of Direct Taxes after an
assessment proceedings has been completed, the requirement