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 agreements under mutual agreement procedure require foreign initiation, authority-to-authority negotiation, and applicant acceptance within thirty days. Bilateral or multilateral advance pricing agreement requests filed in Form No. 3CED under rule 10-I are governed by a mutual agreement procedure. The process begins only if the associated enterprise outside India has already initiated an advance pricing agreement with the foreign competent authority, after which the Indian competent authority ascertains willingness, negotiates acceptable terms, and formalises the arrangement if agreement is reached. The applicant does not participate in inter-authority discussions but must accept or reject the communicated agreement within thirty days.
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Provisions expressly mentioned in the judgment/order text.
Advance pricing agreements under mutual agreement procedure require foreign initiation, authority-to-authority negotiation, and applicant acceptance within thirty days.
Bilateral or multilateral advance pricing agreement requests filed in Form No. 3CED under rule 10-I are governed by a mutual agreement procedure. The process begins only if the associated enterprise outside India has already initiated an advance pricing agreement with the foreign competent authority, after which the Indian competent authority ascertains willingness, negotiates acceptable terms, and formalises the arrangement if agreement is reached. The applicant does not participate in inter-authority discussions but must accept or reject the communicated agreement within thirty days.
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