CBDT signs 95 APAs in FY23
India has filed a total of 516 Advance Pricing Agreement (APA) so far resulting in bringing finality in taxation to income of about ₹ 19,000 crore, according to the APA report released by the Central Board of Direct Taxes (CBDT) on Friday.
The CBDT has signed 95 APA and 32 bilateral APAs in the fiscal year 2022-23, marking the highest number of bilateral agreements filed so far in a year.
It is estimated that the 516 signed APAs have resulted in bringing finality in taxation to income of about ₹19,000 crore. This translates into a payment of tax of about ₹7,000 crore," CBDT said in its fifth APA report.
The best part was that this is litigation-free and does not give rise to appellate proceedings, the report said.
The Advance Pricing Agreement is to promote an investor-friendly and non-adversarial tax regime in India and has contributed significantly to the Centre's's mission of promoting ease of doing business.
Since its commencement in July, 2012, the Advance Pricing Agreement programme has resolved many complex transfer pricing issues which were prone to long drawn and expensive litigation.
Experts say while there's a suggested commitment to provide adequate resources to the APA programme, more action would be welcome.
«The time has come to make the safe harbour programme more attractive so that the pressure on the APA programme can be eased, especially for the simpler cost plus and distribution returns cases,» Eric Mehta, Partner, Price Waterhouse & Co LLP said. The fifth report includes the status of applications filed till March 31.
