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 ... Summary
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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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