Rule 115 lets the Board revise an advance pricing agreement after a change in critical assumptions, a failure to meet a condition, a change in law, or a request from a foreign competent authority, generally only with the assessee's agreement.
115
Rules 2026 · Rule 115
Revision of an agreement (advance pricing agreement)
Rules 77-130
Grounds (sub-rule 1). A change in critical assumptions or a failure to meet a condition; a change in law that modifies a matter covered by the agreement but does not make it non-binding; or a request from the competent authority of the other country, in a bilateral or multilateral case.
How (sub-rules 2 to 7). The Board may revise suo motu or on request of the assessee, the competent authority of India or the Principal Chief Commissioner of Income-tax (International Taxation). Except on the assessee's own request, the agreement is not revised unless the assessee has been heard and agrees; if the assessee does not agree, the agreement may be cancelled under rule 116. If the Board does not agree with an assessee's request, it rejects it in writing with reasons. The procedure in rule 109 may be followed so far as it applies. The revised agreement states the date until which the original applies and the date from which the revised one applies.