Pre-filing consultation under income tax rules clarifies agreement scope, transfer pricing issues, and transaction suitability without binding either side.

An eligible person may apply in Form No. 50 for pre-filing consultation with the Principal Chief Commissioner of Income-tax (International Taxation), and the designated team must hold the consultation. Where the matter involves a bilateral or multilateral agreement, the competent authority of India or its representative must be associated. The consultation covers the scope of the agreement, transfer pricing issues, suitability of the international transaction, and broad terms of the proposed agreement. It does not bind either side or amount to an application for entering into an agreement, and it does not apply to renewal of an agreement.

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