The Advance Pricing Agreement is an agreement signed between the Central Board of Direct Taxes (CBDT) and the taxable person, which sets the subcontracting price or determines how the subcontracting price is to be determined in relation to an international transaction. The contract is valid for a period of five previous consecutive years. This Agreement is binding on the taxable person and the Principal Commissioner/Commissioner, as well as the income tax authorities under his authority, in respect of the person in question and the transaction in question. . . .