notice that it has entered into a Unilateral Advanced Pricing
Agreement ('UAPA') on 04 October 2019 with the Central Board of
Direct Taxes ... above, in case of Bobst India, the date of entering into
the UAPA is 04 October 2019. Accordingly, as per the provisions of
section 92CD
submit that it has entered into a
Unilateral Advance Pricing Agreement ('UAPA") with the Central Board of
Direct Taxes (CBDT ... been
enclosed as Annexure 2).
1. The term of the APA
The UAPA is applicable to consecutive four years commencing
from previous year
assessment year stands covered under the said APA.
2.3.1 As per the UAPA, the assessee agreed and accepted the
royalty rate at 53.5% as determined ... stands subsumed within the term of the
said UAPA, and the assessee is bound by its acceptance of the
53.5% royalty rate for the relevant
position is accepted by the
CBDT in the Unilateral Advance Pricing Agreement (UAPA) as payment
on the Arm's Length Basis the deduction cannot ... file of the AO for verification whether this is accepted by UAPA as
payment on Arm's Length basis. Hence, this issue is restored
Sameer Dnyandev Wankhede vs Narcotics Control Bureau on 13 November, 2025
1 OA No. 18
India. In
this regard, the assessee invited our attention to the UAPA signed for
DCIN wherein complete functions, assets and risks undertaken by DCIN
with
India. In
this regard, the assessee invited our attention to the UAPA signed for
DCIN wherein complete functions, assets and risks undertaken by DCIN
with
India. In
this regard, the assessee invited our attention to the UAPA signed for
DCIN wherein complete functions, assets and risks undertaken by DCIN
with
length remuneration, as agreed in the Unilateral Advance Price
Agreement ("UAPA") dated 20.05.2016 (enclosed in Page 63 of paperbook).
In this regard ... mandated to offer to tax an income of 6.25% as per the UAPA signed with the
Central Board of Direct Taxes ('CBDT').
• From
length remuneration, as agreed in the Unilateral Advance Price
Agreement ("UAPA") dated 20.05.2016 (enclosed in Page 63 of paperbook).
In this regard ... mandated to offer to tax an income of 6.25% as per the UAPA signed with the
Central Board of Direct Taxes ('CBDT').
• From
