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Government of India
Ministry of Finance
Department of Revenue
Central Board of Direct Taxes
New Delhi, 25th March, 2025
Press Release
CBDT notifies amendments in Income-tax Rules, 1962 to expand the scope of safe harbour rules
Section 92CB of the Income-tax Act, 1961 inter alia, empowers the CBDT to make safe harbour rules, for the determination of arm's length price under section 92C or section 92CA.
The scope of the safe harbour rules has been expanded by -:
(a) Increasing the threshold for availing safe harbour from Rs. 200 Crore to Rs. 300 Crore;
(b) Including the “lithium ion batteries for use in electric or hybrid electric vehicles” in the definition of core auto components.
To provide tax certainty to the assessees opting for safe harbour, the amendments are applicable to two assessment years 2025-26 and 2026-27.
CBDT Notification No. 21/2025 dated 25.03.2025 has been published in https://egazette.gov.in/
(V. Rajitha)
Commissioner of Income Tax
(Media & Technical Policy) & Official Spokesperson, CBDT
Safe harbour rules expanded to broaden eligibility and include electric vehicle battery components, enhancing transfer pricing certainty. CBDT has amended the Income-tax Rules to expand the safe harbour rules for transfer pricing by increasing the eligibility threshold and including lithium ion batteries for use in electric or hybrid electric vehicles within the definition of core auto components; these amendments are applied for two specified assessment years to provide tax certainty for assessees opting for the safe harbour mechanism. of Press 'Enter' after typing page number.
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