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: Competent Authority's resolution requires taxpayer acceptance and appeal withdrawal before implementation by assessing officer. Mutual Agreement Procedure requires the Competent Authority in India to examine records and seek resolution with the foreign competent authority. Resolutions reached must be communicated to the Chief Commissioner or Director-General of Income-tax, and the Assessing Officer shall give effect to such resolutions once the taxpayer accepts the resolution and withdraws any related appeal; previously determined tax, interest or penalty amounts are adjusted to conform with the resolution subject to applicable provisions of the Income-tax Act and rules.
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: Competent Authority's resolution requires taxpayer acceptance and appeal withdrawal before implementation by assessing officer.
Mutual Agreement Procedure requires the Competent Authority in India to examine records and seek resolution with the foreign competent authority. Resolutions reached must be communicated to the Chief Commissioner or Director-General of Income-tax, and the Assessing Officer shall give effect to such resolutions once the taxpayer accepts the resolution and withdraws any related appeal; previously determined tax, interest or penalty amounts are adjusted to conform with the resolution subject to applicable provisions of the Income-tax Act and rules.
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