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)
Safe harbour transfer pricing rules set benchmark margins, interest rates and compliance conditions for eligible international transactions. Safe harbour applies to eligible international transactions where the assessee's option is valid and the declared transfer price meets the prescribed margins, interest rates or commission rates for specified categories such as software development, IT enabled services, KPO, intra-group loans, corporate guarantees, contract research and development, auto components and low value-adding intra-group services. The rule also sets out reference rates, credit rating rules, applicable assessment years, the assessee's right to choose the more beneficial option, and provides that no comparability adjustment is made to a transfer price accepted under safe harbour, while sections 92D and 92E continue to apply.
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 transfer pricing rules set benchmark margins, interest rates and compliance conditions for eligible international transactions.
Safe harbour applies to eligible international transactions where the assessee's option is valid and the declared transfer price meets the prescribed margins, interest rates or commission rates for specified categories such as software development, IT enabled services, KPO, intra-group loans, corporate guarantees, contract research and development, auto components and low value-adding intra-group services. The rule also sets out reference rates, credit rating rules, applicable assessment years, the assessee's right to choose the more beneficial option, and provides that no comparability adjustment is made to a transfer price accepted under safe harbour, while sections 92D and 92E continue to apply.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
