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 once transfer pricing is accepted under the safe harbour framework for eligible transactions. Rule 10TG provides that where the transfer price in relation to an eligible international transaction declared by an eligible assessee is accepted by the income-tax authorities under section 92CB, the assessee is not entitled to invoke the mutual agreement procedure under an agreement for avoidance of double taxation with a country or specified territory outside India under sections 90 or 90A.
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 once transfer pricing is accepted under the safe harbour framework for eligible transactions.
Rule 10TG provides that where the transfer price in relation to an eligible international transaction declared by an eligible assessee is accepted by the income-tax authorities under section 92CB, the assessee is not entitled to invoke the mutual agreement procedure under an agreement for avoidance of double taxation with a country or specified territory outside India under sections 90 or 90A.
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