Income-tax Rules, 2026

Rule 103Meaning of expressions used in matters in respect of advance pricing agreement

Income-tax Rules, 2026 · G.S.R. 198(E), dated 20-03-2026

For the purposes of this rule and rules 104 to 120, —

(a)"agreement' means an advance pricing agreement entered into between the Board and the applicant, with the approval of the Central Government, as referred to in section 168(1);

(b)"application" means an application for advance pricing agreement made under rule 106;

(c)"applicant" means a person who has made an application;

(d)"bilateral agreement" means an agreement between the Board and the applicant, subsequent to, and based on, any agreement referred to in rule 122 between the competent authority of India with the competent authority of the other country regarding the most appropriate transfer pricing method or the arms' length price;

(e)"competent authority of India" means an officer authorised by the Central Government for the purpose of discharging the functions relating to any agreement entered into under section 159 of the Act;

(f)"covered transaction" means the international transaction or transactions for which agreement has been entered into;

(g)"critical assumptions" means the factors and assumptions which are so critical and significant, that if changed, the parties to the agreement shall not continue to be bound by the agreement;

(h)"most appropriate transfer pricing method" means a transfer pricing method, referred to in section 165(1), being the most appropriate, having regard to the nature of transaction or class of transaction or class of associated persons or function performed by such persons or such other relevant factors specified by the Board under rules 79 and 80;

(i)"multilateral agreement" means an agreement between the Board and the applicant, subsequent to, and based on, any agreement referred to in rule 122 between the competent authority of India with the competent authorities of the other countries regarding the most appropriate transfer pricing method or the arms' length price;

(j)"rollback year" means any tax year, falling within the period not exceeding four tax years, preceding the first of the tax years referred to in section 168(4);

(k)"tax treaty" means an agreement under section 159 for the avoidance of double taxation;

(l)"team" means advance pricing agreement team consisting of income-tax authorities as constituted by the Board and including such number of experts in economics, statistics, law or any other field as may be nominated by the Principal Chief Commissioner of Income-tax (International Taxation); and

(m)"unilateral agreement" means an agreement between the Board and the applicant, which is neither a bilateral nor a multilateral agreement.

This rule refers to

Rule 106 Application for advance pricing agreement

Rule 122 Procedure to deal with requests for bilateral or multilateral advance pricing agreements

Rule 104 Persons eligible to apply

Rule 105 Pre-filing consultation

Rule 106 Application for advance pricing agreement

Rule 107 Withdrawal of application for agreement

Rule 108 Preliminary processing of application

Rule 109 Procedure

Rule 110 Terms of the agreement

Rule 111 Roll back of Agreement

Rule 112 Amendments to application

Rule 113 Furnishing of annual compliance report

Rule 114 Compliance audit of agreement

Rule 115 Revision of an agreement

Rule 116 Cancellation of an agreement

Rule 117 Procedure for giving effect to rollback provision of an Agreement

Rule 118 Relief in tax payable under section 206(1) due to operation of section 206(1)(i)

Rule 119 Renewing an agreement

Rule 120 Miscellaneous

Rule 79 Determination of arm's length price under section 165

Rule 80 Most appropriate method

§ 159 Agreement with foreign countries or specified territories and adoption by Central Government of agreement between specified associations for double taxation relief

§ 165 Determination of arm’s length price

§ 168 Advance pricing agreement