<transcript><audio_64>not of that value so in that way the the the tax tax revenue tax was debated so now this advanced pricing agreement the it determines the transfer pricing methodology in advance so it provides certainty with respect to the test tax</transcript><video><caption><image_65>The image is a screenshot of a document titled "An APA is an agreement between a taxpayer and the tax authority determining the Transfer Pricing Methodology for pricing the tax payer's international transactions for future years. Purpose: An APA provides certainty with respect to the tax outcome of the tax papers international transactions. Statutory basis: The Finance Act, 2012, inserted sections 92C and 92CD in the ITA to provide the legal basis for APA in India. An APA can be one of the three types - unilateral, bilateral and multilateral.</caption><caption><image_66>The image is a document titled "An APA is an agreement between a taxpayer and the tax authority determining the Transfer Pricing methodology for pricing the tax payer's international transactions for future years." The document is written in black text on a white background. 

The document is divided into three sections. The first section is titled "Purpose: An APA provides certainty with respect to the tax outcome of the tax payer international transactions." The second section is "Statutory basis: The Finance Act, 2012, inserted sections 9SC and CD in the ITA to provide the legal basis for APA in India." The third section is labeled "An APA can be one of the three types - unilateral, bilateral and multilateral".

At the bottom of the document, there is a signature that reads "V".</caption></video><transcript><audio_67>outcome of the taxpayers international transactions so it is a statutory basis that is Finance Act 2012 inserted fractions 1992 CC and 92 CD in de this Income Tax Act to provide the legal</transcript><caption><image_68>The image is a screenshot of a document titled "Statutory basis: The Finance Act, 2012, inserted sections 9CC and 92 CD in the ITA to provide the legal basis for APA in India". The document is written in black text on a white background. The text is divided into three sections.

The first section is titled "An APA can be one of the three types - unilateral, bilateral, and multilateral". The second section is labeled "Unilateral APA is an APA that involves only the taxpayer and the tax authority of the country where the taxpayer is located. The third section is labelled "Bilateral APAA (BAPA) is an API that involves the tax paper, associated enterprise (AEP) of the taxpayer in the foreign country, tax authority, and foreign country. The document appears to be a statement or a statement of some kind.</caption> not of that value so in that way the the the tax tax revenue tax was debated so now this advanced pricing agreement the it determines the transfer pricing methodology in advance so it provides certainty with respect to the test tax outcome of the taxpayers international transactions so it is a statutory basis that is Finance Act 2012 inserted fractions 1992 CC and 92 CD in de this Income Tax Act to provide the legal
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