Safe harbour for specified domestic transactions defines when declared transfer prices are accepted and bars comparability adjustments. Safe harbour applies to an eligible specified domestic transaction where the transfer price declared by an eligible assessee is accepted if the option is validly exercised and the transaction falls within the prescribed circumstances. Electricity transactions require tariff determination or approval by the Appropriate Commission, while milk or milk products must be priced according to quality-based parameters and transparently declared. No comparability adjustment or allowance under section 165(3)(a)(ii) applies to an accepted transfer price, and sections 171 and 172 continue to apply notwithstanding the safe harbour option.
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.
Safe harbour for specified domestic transactions defines when declared transfer prices are accepted and bars comparability adjustments.
Safe harbour applies to an eligible specified domestic transaction where the transfer price declared by an eligible assessee is accepted if the option is validly exercised and the transaction falls within the prescribed circumstances. Electricity transactions require tariff determination or approval by the Appropriate Commission, while milk or milk products must be priced according to quality-based parameters and transparently declared. No comparability adjustment or allowance under section 165(3)(a)(ii) applies to an accepted transfer price, and sections 171 and 172 continue to apply notwithstanding the safe harbour option.
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