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CBDT signs record number of 125 Advance Pricing Agreements (APAs) in FY 2023-24

The Central Board of Direct Taxes (CBDT) has entered into a record 125 Advance Pricing Agreements (APAs) in FY 2023-24 with Indian taxpayers. This includes 86 Unilateral APAs (UAPAs) and 39 Bilateral APAs (BAPAs). This marks the highest ever APA signings in any financial year since the launch of the APA programme. The number of APAs signed in FY 2023-24 also represents a 31% increase compared to the 95 APAs signed during the preceding financial year. With this, the total number of APAs since inception of the APA programme has gone up to 641, comprising 506 UAPAs and 135 BAPAs.

During FY 2023-24 CBDT also signed the maximum number of BAPAs in any financial year till date. The BAPAs were signed as a consequence of entering into Mutual Agreements with India’s treaty partners namely Australia, Canada, Denmark, Japan, Singapore, the UK and the US.

The APA Scheme endeavours to provide certainty to taxpayers in the domain of transfer pricing by specifying the methods of pricing and determining the arm’s length price of international transactions in advance for a maximum of five future years. Further, the taxpayer has the option to rollback the APA for four preceding years, as a result of which, tax certainty is provided for nine years. The signing of bilateral APAs additionally provides the taxpayers with protection from any anticipated or actual double taxation.

The APA programme has contributed significantly to the Government of India’s mission of promoting ease of doing business, especially for Multi National Enterprises () which have a large number of cross-border transactions within their group entities.

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Auction for Sale (issue/ re-issue) of (i) ‘7.37% GS 2028’ and (ii) ‘New GS 2064’

The Government of India (GoI) has announced the sale (issue/ re-issue) of (i) “7.37% Government Security 2028” for a notified amount of Rs. 12,000 crore (nominal) through price based auction using multiple price method, and (ii) “New Government Security 2064” for a notified amount of Rs. 12,000 crore (nominal) through yield based auction using multiple price method. GoI will have the option to retain additional subscription up to Rs. 2,000 crore against each security mentioned above. The auctions will be conducted by the Reserve Bank of India, Mumbai Office, Fort, Mumbai on April 19, 2024 (Friday).

Up to 5% of the notified amount of the sale of the securities will be allotted to eligible individuals and institutions as per the Scheme for Non-Competitive Bidding Facility in the Auction of Government Securities.

Both competitive and non-competitive bids for the auction should be submitted in electronic format on the Reserve Bank of India Core Banking Solution (E-Kuber) system on April 19, 2024. The non-competitive bids should be submitted between 10:30 a.m. and 11:00 a.m. and the competitive bids should be submitted between 10:30 a.m. and 11:30 a.m.

The result of the auctions will be announced on April 19, 2024 (Friday) and payment by successful bidders will be on April 22, 2024 (Monday).

The Securities will be eligible for “When Issued” trading in accordance with the guidelines on ‘When Issued transactions in Central Government Securities’ issued by the Reserve Bank of India vide circular No. RBI/2018-19/25 dated July 24, 2018 as amended from time to time.

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RBI announces Decision on two applications received under Guidelines for ‘on tap’ Licensing of Small Finance Banks

The Reserve Bank has received 13 applications to set up bank under the Guidelines for 'on tap' Licensing of Universal Banks and Small Finance Banks. The names of these applicants were given in the press releases on April 15August 30December 31, 2021January 04, 2023 and January 08, 2024. The decision on nine of these applications was announced vide press releases on May 17, 2022 and July 04, 2023.

The examination of two more applications for setting-up a small finance bank has been completed as per the procedure laid down under extant guidelines. Based on the assessment of the applications, the following applicants were not found suitable for granting of in-principle approval to set up a small finance bank:

  1. Dvara Kshetriya Gramin Financial Services Private Limited
  2. Tally Solutions Private Limited

The remaining two applications are under examination.

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