Highlights Of CBDT's 4th And 5th Annual Report On APA Program

The Advance Pricing Agreement (APA) program has been proven to be an effective tool for dispute resolution since its inception in 2012 in India. The 4^th Annual Report encapsulating FYs 2019-20, 2020-21 and 2021-22 and 5^th Annual Report which was released within a span of three days encapsulating FY 2022-23 clearly highlights the progress made by the Central Board of Direct Taxes (CBDT) in entering into the APAs. The last annual report was issued in November 2019, covering the statistics till FY 2018-19¹.

The summary of the number of applications filed and the number of agreements signed (year-wise) is given below for ease of reference:

The number of agreements signed during FY 20-21 reflected a significant fall due to the spread of COVID-19, which immediately bounced back in the later years to hit a record high in FY 22-23. It is also interesting to note that taxpayers now prefer Bilateral APAs (BAPAs) over Unilateral APAs (UAPAs) to ensure bilateral