Rule 10TIA - Safe Harbour

Safe harbour for raw diamond sales restricts post-election deductions and disallows certain set-offs while transfer pricing rules apply.

Safe harbour under Rule 10TIA allows acceptance of an eligible assessee's election under rule 10TIB for selling raw diamonds when the declared profits satisfy the specified circumstance, subject to invalidation under rule 10TIB; on election, deductions under sections 30-38 are deemed fully given, written down value is computed as if depreciation were allowed, unabsorbed depreciation and carried forward losses cannot be set off, losses from other business or heads cannot be set off against income of that business, and sections 92D and 92E apply to international transactions as defined by section 92B.