Power of Board to make Safe Harbour Rules - Section 92CB read with Rule 10TD of income Tax Rules

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.