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          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.

          <h1>Safe harbour option: filing Form 3CEFA secures specified transfer pricing margins subject to verification and timelines.</h1> The rule requires an assessee to file Form 3CEFA by the return due date to exercise a safe harbour option for eligible international transactions; the Assessing Officer verifies eligibility and may refer doubts to the Transfer Pricing Officer who can require documents and declare the option invalid after a hearing. The assessee may object to the Commissioner who decides on validity. If valid, the Assessing Officer checks conformity with the specified safe harbour margins and may adopt the prescribed margins; strict time limits apply and failure to act results in deemed validity.

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