Safe harbour rules allow declared transfer prices to be accepted, making arm's length determinations subject to prescribed rules. The Bill inserts section 92CB empowering the Board to make safe harbour rules so that determination of arm's length price under sections 92C and 92CA is subject to safe harbour; 'safe harbour' is defined as circumstances in which income tax authorities shall accept the transfer price declared by the assessee, and the amendment is to operate retrospectively from 1 April 2009.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Safe harbour rules allow declared transfer prices to be accepted, making arm's length determinations subject to prescribed rules.
The Bill inserts section 92CB empowering the Board to make safe harbour rules so that determination of arm's length price under sections 92C and 92CA is subject to safe harbour; "safe harbour" is defined as circumstances in which income tax authorities shall accept the transfer price declared by the assessee, and the amendment is to operate retrospectively from 1 April 2009.
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