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The APA regime has significantly strengthened Indiau2019s transfer pricing framework by enhancing certainty and reducing litigation. However, challenges remainu2014such as the limited uptake of unilateral APAs. To fully realize its potential, reforms aimed at boosting efficiency, transparency, and fairness are essential. Strengthening the APA system will not only help resolve tax disputes more effectively but also create a stable and attractive environment for multinational companies seeking long-term tax certainty and encouraging foreign investment.
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