103. Meaning of expressions used in matters in respect of advance pricing agreement.—

For the purposes of this rule and rules 104 to 120, —

(a) ?agreement‘ means an advance pricing agreement entered into between the Board and the applicant, with the approval of the Central Government, as referred to in section 168(1);

(b) ?application? means an application for advance pricing agreement made under rule 106;

(c) ?applicant? means a person who has made an application;

(d) ?bilateral agreement? means an agreement between the Board and the applicant, subsequent to, and based on, any agreement referred to in rule 122 between the competent authority of India with the competent authority of the other country regarding the most appropriate transfer pricing method or the arms' length price;

(e) ?competent authority of India? means an officer authorised by the Central Government for the

purpose of discharging the functions relating to any agreement entered into under section 159 of the Act;

(f) ?covered transaction? means the international transaction or transactions for which agreement has been entered into;

(g) ?critical assumptions? means the factors and assumptions which are so critical and significant, that if changed, the parties to the agreement shall not continue to be bound by the agreement;

(h) ?most appropriate transfer pricing method? means a transfer pricing method, referred to in section 165(1), being the most appropriate, having regard to the nature of transaction or class of transaction or class of associated persons or function performed by such persons or such other relevant factors specified by the Board under rules 79 and 80;

(i) ?multilateral agreement? means an agreement between the Board and the applicant, subsequent to,and based on, any agreement referred to in rule 122 between the competent authority of India with the competent authorities of the other countries regarding the most appropriate transfer pricing method or the arms' length price;

(j) ?rollback year? means any tax year, falling within the period not exceeding four tax years,

preceding the first of the tax years referred to in section 168(4);

(k) ?tax treaty? means an agreement under section 159 for the avoidance of double taxation;

(l) ?team? means advance pricing agreement team consisting of income-tax authorities as constituted by the Board and including such number of experts in economics, statistics, law or any other field as may be nominated by the Principal Chief Commissioner of Income-tax (International Taxation); and

(m) "unilateral agreement" means an agreement between the Board and the applicant, which is neither a bilateral nor a multilateral agreement.