Mutual agreement procedure barred after safe harbour acceptance for eligible international transactions under transfer pricing rules.

Where the transfer price for an eligible international transaction declared by an eligible assessee is accepted by the income-tax authorities under the safe harbour provisions, the assessee is not entitled to invoke the mutual agreement procedure under a double taxation avoidance agreement with a country or specified territory outside India. The rule links acceptance under the safe harbour regime with a bar on recourse to treaty-based dispute resolution in respect of the same transaction.

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