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)
Transfer pricing documentation requirement: constituent entities must maintain and file a group master file by the tax return due date. Constituent entities of an international group exceeding specified thresholds must maintain a comprehensive master file including group entity lists, ownership charts, business descriptions, transfer-pricing policies for services, intangibles and financing, financing arrangements and central financing entities, consolidated financial statements, and descriptions of significant restructurings; Part A of the prescribed form must be furnished even if thresholds are unmet, and the master file must be retained for eight years with electronic filing and security procedures specified by the tax systems authority.
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.
Transfer pricing documentation requirement: constituent entities must maintain and file a group master file by the tax return due date.
Constituent entities of an international group exceeding specified thresholds must maintain a comprehensive master file including group entity lists, ownership charts, business descriptions, transfer-pricing policies for services, intangibles and financing, financing arrangements and central financing entities, consolidated financial statements, and descriptions of significant restructurings; Part A of the prescribed form must be furnished even if thresholds are unmet, and the master file must be retained for eight years with electronic filing and security procedures specified by the tax systems authority.
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