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 for international transactions requires Form 3CEFA filing, eligibility verification, and time-bound transfer pricing scrutiny. Safe harbour for international transactions is exercised by furnishing Form 3CEFA complete in all respects to the Assessing Officer within the prescribed due date for the return of income, and the option continues for the stated period or five years, whichever is less, subject to annual statements for later years. The Assessing Officer must verify eligibility of the assessee and the international transaction, and any doubt may be referred to the Transfer Pricing Officer, who may call for information and, after hearing the assessee, declare the option invalid if the assessee or transaction is ineligible or the required material is not furnished. Objections lie to the Commissioner, and if the option is upheld the declared transfer price is tested against the safe harbour circumstances. Time limits apply to references and orders, failing which the option is treated as valid.
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 for international transactions requires Form 3CEFA filing, eligibility verification, and time-bound transfer pricing scrutiny.
Safe harbour for international transactions is exercised by furnishing Form 3CEFA complete in all respects to the Assessing Officer within the prescribed due date for the return of income, and the option continues for the stated period or five years, whichever is less, subject to annual statements for later years. The Assessing Officer must verify eligibility of the assessee and the international transaction, and any doubt may be referred to the Transfer Pricing Officer, who may call for information and, after hearing the assessee, declare the option invalid if the assessee or transaction is ineligible or the required material is not furnished. Objections lie to the Commissioner, and if the option is upheld the declared transfer price is tested against the safe harbour circumstances. Time limits apply to references and orders, failing which the option is treated as valid.
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