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of The CBDT's Income-tax (Sixth Amendment) Rules, 2025 expands safe harbour provisions for international transactions. The definition of 'core auto components' under Rule 10TA now includes lithium ion batteries for electric/hybrid vehicles. Rule 10TD increases the monetary threshold for eligible international transactions from two crore to three crore rupees across multiple categories. The applicability period for safe harbour provisions has been extended to include assessment years 2025-26 and 2026-27. Rule 10TE now specifies that applications under Rule 10TD are valid for one assessment year. These amendments aim to modernize transfer pricing regulations to accommodate emerging technologies and provide greater taxpayer certainty.
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