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 under income tax rules covered treaty-based resolution, implementation, and adjustment of determined tax dues. Rule 44H has been omitted. Before omission, it dealt with the mutual agreement procedure by requiring the Competent Authority of India to examine references from a foreign competent authority, endeavour to resolve the case under the applicable agreement, and communicate the resolution for implementation. The Assessing Officer was to give effect to the resolution within ninety days, subject to the assessee's acceptance and withdrawal of any pending appeal. The rule also provided for adjustment of tax, interest, or penalty already determined, and defined the Competent Authority of India as an officer authorised by the Central Government.
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 under income tax rules covered treaty-based resolution, implementation, and adjustment of determined tax dues.
Rule 44H has been omitted. Before omission, it dealt with the mutual agreement procedure by requiring the Competent Authority of India to examine references from a foreign competent authority, endeavour to resolve the case under the applicable agreement, and communicate the resolution for implementation. The Assessing Officer was to give effect to the resolution within ninety days, subject to the assessee's acceptance and withdrawal of any pending appeal. The rule also provided for adjustment of tax, interest, or penalty already determined, and defined the Competent Authority of India as an officer authorised by the Central Government.
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