Examination and Analysis of an APA Application - International Taxation - Income Tax

Examination and Analysis of an APA Application Since proper functional analysis, determination of transfer pricing methodology, examination of critical assumptions and specifying the manner in which the arm's length price is to be determined are key to the success of the APA programme, power has been given to the APA team and the competent authority to hold meetings, call for additional document. information, visit applicant's business premises and make enquiries under Rule 10L(2) . it shall be competent for the team or the competent authority in India or its representative to- ( i ) hold meetings with the applicant on such time and date as it deem fit; ( ii ) call for additional document or information or material from the applicant; ( iii ) visit the applicant's business premises; or ( iv ) make such inquiries as it deems fit in the circumstances of the case. The applicant is expected to give full cooperation for this purpose. The APA team is required to do detailed functional analysis and examine the APA application in a reasonable and fair manner taking into consideration all the evidences and information produced by the applicant or collected by it.