Rule 111 allows an agreement to apply to up to four earlier tax years (rollback years) for the same transaction, on conditions about returns and reports filed in time, all rollback years being requested, and no appeal decided by the Appellate Tribunal or reduction of declared income, with an additional fee.
111
Rules 2026 · Rule 111
Roll back of Agreement (advance pricing agreement)
Rules 77-130
The rollback provision (sub-rule 1). The agreement may provide for determining the arm's length price, or the manner of determining it, in the rollback year.
Conditions (sub-rule 2). The international transaction is the same as the one covered by the agreement; the return for the rollback year has been or is furnished in time under section 263(1)(c), and so has the report for the transaction; rollback is requested for all the rollback years in which the transaction was undertaken; and the request is made in Form No. 51 as sub-rule (5) provides.
When it is not available (sub-rule 3). If the arm's length price for the year has been the subject of an appeal before the Appellate Tribunal and the Tribunal has disposed of the appeal before the agreement is signed, or if applying rollback would reduce the total income or increase the loss the applicant declared in the return for that year.
Same manner (sub-rule 4). The manner of determining the arm's length price in a rollback year is the same as that agreed for the same transaction in the years the agreement applies to (other than rollback years).
Fee (sub-rule 5). A request for rollback is made with the application, with proof of payment of an additional fee of Rs. 5,00,000.