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)
Mutual Agreement Procedure barred where transfer price accepted under safe harbour, preventing treaty MAP invocation by the assessee. Mutual Agreement Procedure is excluded where the transfer price for an eligible international transaction declared by an eligible assessee is accepted by the income-tax authorities under the safe harbour framework, preventing invocation of treaty-based MAP remedies for transactions and assessees meeting the prescribed eligibility criteria.
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.
Mutual Agreement Procedure barred where transfer price accepted under safe harbour, preventing treaty MAP invocation by the assessee.
Mutual Agreement Procedure is excluded where the transfer price for an eligible international transaction declared by an eligible assessee is accepted by the income-tax authorities under the safe harbour framework, preventing invocation of treaty-based MAP remedies for transactions and assessees meeting the prescribed eligibility criteria.
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