On 10 June 2015, India's Central Board of Direct Taxes issued a FAQ to provide clarification on the rollback provisions for advance pricing agreements. Some of the main issued covered are summarized as follows.
Rollback for Same Transactions
For the rollback provisions to apply, the transactions covered must be the same as the transactions covered by the APA for future years. The FAQ explains that this means that the transaction in the rollback year has to be of same nature and undertaken …