Audit exemption allowed by the taxman for MNCs subject to their declaring transaction prices above specified thresholds would be available for past transactions only with inflation adjustments.Under the advance pricing agreement (APA), a facility built into the income tax law to avoid litigation to the extent possible, an MNC can get audit exemption either by a mutual agreement with the taxman on the arm's length price of cross-border transactions or the profit margins they need to declare in India regarding such transactions.

Source - http://www.financialexpress.com