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)
Bilateral advance pricing agreements require counterpart willingness and mutual agreement negotiation before formalising APA arrangements. Procedure governs bilateral or multilateral Advance Pricing Agreements filed in Form No. 3 CED; initiation requires the associated foreign enterprise to have commenced APA procedures abroad. The Indian competent authority must seek counterpart willingness, negotiate mutually acceptable terms with other competent authorities, formalise a Mutual Agreement Procedure arrangement if agreement is reached, and notify the applicant, who must accept or reject within thirty days. The applicant may not join competent authority discussions but may communicate with the Indian competent authority, and may proceed with an APA outside the mutual agreement process or withdraw under rule 10J if the mutual agreement is not acceptable.
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.
Bilateral advance pricing agreements require counterpart willingness and mutual agreement negotiation before formalising APA arrangements.
Procedure governs bilateral or multilateral Advance Pricing Agreements filed in Form No. 3 CED; initiation requires the associated foreign enterprise to have commenced APA procedures abroad. The Indian competent authority must seek counterpart willingness, negotiate mutually acceptable terms with other competent authorities, formalise a Mutual Agreement Procedure arrangement if agreement is reached, and notify the applicant, who must accept or reject within thirty days. The applicant may not join competent authority discussions but may communicate with the Indian competent authority, and may proceed with an APA outside the mutual agreement process or withdraw under rule 10J if the mutual agreement is not acceptable.
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