Part DCA - Safe Harbour Rules for income referred to in clause (i) of sub-section (1) of section 9 chargeable to tax under the head (From Rule 10TI to Rule 10TIC)
Compliance audit of advance pricing agreements requires yearly review, supporting evidence, timely reporting, and limits regular audit of covered transactions. Rule 10P requires the Transfer Pricing Officer to carry out a yearly compliance audit of each year covered by an advance pricing agreement and may call for evidence showing compliance with the agreement's terms, critical assumptions, supporting data, and transfer pricing method. The officer must submit a compliance audit report within six months of receiving the Annual Compliance Report, and regular audit of covered transactions is barred where an agreement exists, except after cancellation.
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Provisions expressly mentioned in the judgment/order text.
Compliance audit of advance pricing agreements requires yearly review, supporting evidence, timely reporting, and limits regular audit of covered transactions.
Rule 10P requires the Transfer Pricing Officer to carry out a yearly compliance audit of each year covered by an advance pricing agreement and may call for evidence showing compliance with the agreement's terms, critical assumptions, supporting data, and transfer pricing method. The officer must submit a compliance audit report within six months of receiving the Annual Compliance Report, and regular audit of covered transactions is barred where an agreement exists, except after cancellation.
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