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)
Advance Pricing Agreement application does not suspend arm's length price determination and negotiations follow applicable tax treaties. Mere filing of an application for an Advance Pricing Agreement does not prevent operation of Chapter X for determination of the arm's length price until the agreement is entered into. Negotiation of bilateral or multilateral agreements between the Indian competent authority and foreign competent authorities must be conducted in accordance with the applicable tax treaty provisions.
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.
Advance Pricing Agreement application does not suspend arm's length price determination and negotiations follow applicable tax treaties.
Mere filing of an application for an Advance Pricing Agreement does not prevent operation of Chapter X for determination of the arm's length price until the agreement is entered into. Negotiation of bilateral or multilateral agreements between the Indian competent authority and foreign competent authorities must be conducted in accordance with the applicable tax treaty provisions.
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