An article stating that IT-BPO companies and their tax advisors are hoping that the Advance Pricing Agreement (APA) which is provided for in the Direct Taxes Code to deal with transfer pricing matters will be introduced in the forthcoming Budget. They say the Indian tax department is becoming increasingly aggressive in determining arms length profit margins for the software and ITeS industries. Over Rs 40,000 crore is estimated to be locked up in such disputes. The article quotes Mr. Som Mittal, President, NASSCOM, stating that transfer pricing rules are being applied inconsistently across the country. There is secrecy all around. Thirty-five per cent of Indian outsourcing revenues come from captive units of MNCs here. In some cases tax authorities have even sought to tax global profits in India.