The Central Board of Direct Taxes (CBDT) on 28 March 2016 signed 11 unilateral Advance Pricing Agreements (APAs). With this, India entered into 59 unilateral/bilateral APAs.
•    The APA programme was introduced by the Finance Act, 2012 to provide a predictable and non-adversarial tax regime and to reduce litigation in the Indian transfer pricing regime. 50 of these agreements were signed in the financial year 2015-16.
•    It covers a range of international transactions, including corporate guarantees, royalty, software development services, IT enabled services and trading.
•    It pertains to different industrial sectors like telecom, media, automobiles, IT services, and others. 
•    Some of the agreements have rollback provisions and provide certainty to the taxpayers for 9 years with regard to the covered international transactions.
•    Rollback provisions in APAs were introduced in the July 2014 Budget to provide certainty on the pricing of international transactions for 4 years (rollback years) preceding the first year from which APA becomes applicable. 
•    With the notification of Rollback rules in March 2015, the taxpayer has been provided the option to choose certainty in transfer pricing matters with the Government for a total of nine years (5 future years and 4 prior years).
•    Since the notification of the APA scheme on 30 August 2012, approximately 580 applications for APAs have been received and about half of these contain a request for the Rollback provisions. 
•    The number of applications is indicative of the wide international and national appreciation of the India’s APA programme’s ability to address complex transfer pricing issues in a fair and transparent manner.