106. Application for advance pricing agreement.—

(1) An eligible person may furnish an application in Form No. 51 along with requisite fee of twenty lakh rupees for entering into an agreement.

(2) The application shall be furnished to Principal Chief Commissioner of Income-tax (International Taxation) in case of unilateral agreement and to the competent authority of India, in case of bilateral or multilateral agreement.

(3) The application may be filed by the eligible person at any time—

(a) before the first day of the first tax year for which the application is made, in respect of transactions which are of a continuing nature from dealings that are already occurring; or

(b) before undertaking the transaction in respect of remaining transactions.

(4) The application shall be accompanied by the proof of payment of fees of twenty lakh rupees.