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

Definitions.

• Agreement: an advance pricing agreement between the Board and the applicant, with the Central Government's approval, as referred to in section 168(1).
• Application and applicant: an application under rule 106 and the person who makes it.
• Unilateral, bilateral and multilateral agreement: a bilateral or multilateral agreement is one between the Board and the applicant that follows and is based on an agreement under rule 122 between the competent authority of India and the competent authority of one other country (bilateral) or other countries (multilateral) on the most appropriate transfer pricing method or the arm's length price. A unilateral agreement is neither.
• Competent authority of India: an officer authorised by the Central Government to discharge the functions relating to agreements under section 159.
• Covered transaction: the international transaction or transactions for which the agreement has been entered into.
• Critical assumptions: the factors and assumptions so critical that, if changed, the parties are no longer bound by the agreement.
• Most appropriate transfer pricing method: a method referred to in section 165(1), having regard to the nature of the transaction, class of associated persons, functions performed and other factors specified by the Board under rules 79 and 80.
• Rollback year: any tax year within a period not exceeding four tax years preceding the first of the tax years referred to in section 168(4).
• Tax treaty: an agreement under section 159 for the avoidance of double taxation.
• Team: the advance pricing agreement team of income-tax authorities constituted by the Board, including experts in economics, statistics, law or other fields nominated by the Principal Chief Commissioner of Income-tax (International Taxation).