Provisions relating to Advance Pricing Agreements (APAs) were introduced in the Indian Income-tax Act, 1961, with effect from 1 July 2012, vide Finance Act, 2012. These provisions did not then include rollback provisions. The provision to provide for a rollback mechanism was brought into the Act vide Finance Act 2014, with effect from 1 October 2014. Thereafter, in March 2015, the Central Board of Direct Taxes (CBDT) announced detailed rules explaining the rollback provisions, and the procedure for giving effect to them.
Subsequent to the Rules being notified, the CBDT received several requests for clarifications regarding certain matters. To address these, the CBDT has now issued clarifications in a Question and Answer format.
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