Safe harbour rules accepting declared transfer price when eligibility, filing and verification conditions are satisfied, limiting transfer pricing adjustments. Safe harbour rules allow tax authorities to accept a taxpayer's declared transfer price for specified eligible international transactions if prescribed eligibility, transactional and procedural conditions are met and the assessee files Form 3CEFA; the Assessing Officer verifies eligibility and may refer doubts to the Transfer Pricing Officer, whose orders declaring invalidity are subject to objection to the Commissioner and are bound by statutory time limits, and when validly applied the declared margins or rates are accepted without comparability adjustments.
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 rules accepting declared transfer price when eligibility, filing and verification conditions are satisfied, limiting transfer pricing adjustments.
Safe harbour rules allow tax authorities to accept a taxpayer's declared transfer price for specified eligible international transactions if prescribed eligibility, transactional and procedural conditions are met and the assessee files Form 3CEFA; the Assessing Officer verifies eligibility and may refer doubts to the Transfer Pricing Officer, whose orders declaring invalidity are subject to objection to the Commissioner and are bound by statutory time limits, and when validly applied the declared margins or rates are accepted without comparability adjustments.
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