Under section 168 of the Income-tax Act, 2025, an agreement entered into by the Board, with the…

Section 168(1) of the Income-tax Act, 2025 empowers the Board, with the approval of the Central Government, to enter into "an advance pricing agreement" with any person determining the arm's length price, or the manner of determining it, for an international transaction to be entered into by that person. It fixes the pricing in advance for future transactions, unlike a double taxation avoidance agreement under section 159, which is made between governments. This corresponds to section 92CC of the repealed Income-tax Act, 1961.