Rule 106 sets how to apply for an advance pricing agreement: Form No. 51 with a fee of twenty lakh rupees, to the Principal Chief Commissioner of Income-tax (International Taxation) for a unilateral agreement or the competent authority of India for bilateral or multilateral, filed before the first year it covers or before the transaction.
106
Rules 2026 · Rule 106
Application for advance pricing agreement
Rules 77-130
The application. An eligible person furnishes an application in Form No. 51 with the requisite fee of twenty lakh rupees, accompanied by proof of payment (sub-rules 1 and 4). It goes to the Principal Chief Commissioner of Income-tax (International Taxation) for a unilateral agreement, and to the competent authority of India for a bilateral or multilateral agreement (sub-rule 2).
When (sub-rule 3). For transactions of a continuing nature from dealings already occurring, before the first day of the first tax year for which the application is made; for remaining transactions, before undertaking the transaction.