Janak Poly Fibres Ltd. is an Indian company having registered office in Mumbai and John Stuart LLP is a non-resident Singapore base company. There have been a series of international transactions between both these compa

Janak Poly Fibres Ltd. is an Indian company having registered office in Mumbai and John Stuart LLP is a non-resident Singapore base company. There have been a series of international transactions between both these companies since last so many years. Janak Poly Fibres Ltd. has entered into an Advance Pricing Agreement (APA) on 10th January, 2020 to determine the ALP for the transactions entered with John Stuart LLP by stating that P.Y. 2019-20 is the first of the consecutive previous years. The rate adopted under the Advance Pricing Agreement is ₹ 13,500 per MT. The assessments for the assessment years 2012-13 to 2017-18 of Janak Poly Fibres Ltd. have been completed on various dates and in these years, the ALP determined and taken for the A.Y. 2012-13 to 2015-16 was ₹ 13,000 per MT and of ₹ 14,000 per MT for A.Y. 2016-17 and 2017-18. The quantity involved was 2 lakhs MT in each of these years respectively. Assessments for the subsequent assessment years for 2018-19 and 2019-20 are pending and yet to be completed. The assessee had adopted the value of ₹ 13,200 per MT in both the assessment years 2018-19 and 2019-20. In the backdrop of the above and taking note of the aforesaid information, you are required to answer the following; considering the transfer pricing provisions and the provisions contained under the Income Tax Act, 1961: (ii) In the given situation and the set of facts, state the year for which the APA cannot be applied.