TaxTMI 
TaxTMI 
Safe Harbour
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....nto during the previous year does not exceed a sum of five hundred crore rupees; or (ii) not less than 22 per cent., where the aggregate value of such transactions entered into during the previous year exceeds a sum of five hundred crore rupees. 2. Provision of information technology enabled services referred to in item (ii) of rule 10TC. The operating profit margin declared by the eligible assessee from the eligible international transaction in relation to operating expense is - (i) not less than 20 per cent., where the aggregate value of such transactions entered into during the previous year does not exceed a sum of five hundred crore rupees; or (ii) not less than 22 per cent., where the aggregate value of such transactions entered into during the previous year exceeds a sum of five hundred crore rupees. 3. Provision of knowledge process outsourcing services referred to in item (iii) of rule 10TC. The operating profit margin declared by the eligible assessee from the eligible international transaction in relation to operating expense is not less than 25 per cent.. 4. Advancing of intra-group loans referred to in item (iv) of rule 10TC where the amount of loan ....
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....fied in column (2) of the Table below shall be as specified in the corresponding entry in column (3) of the said Table:- Sl. No. Eligible International Transaction Circumstances (1) (2) (3) 1. Provision of software development services referred to in item (i) of rule 10TC. The operating profit margin declared by the eligible assessee from the eligible international transaction in relation to operating expense incurred is - (i) not less than 17 per cent., where the value of international transaction does not exceed a sum of one hundred crore rupees; or (ii) not less than 18 per cent., where the value of international transaction exceeds a sum of one hundred crore rupees but does not exceed a sum of 17[three] hundred crore rupees. 2. Provision of information technology enabled services referred to in item (ii) of rule 10TC. The operating profit margin declared by the eligible assessee from the eligible international transaction in relation to operating expense is - (i) not less than 17 per cent., where the aggregate value of such transactions entered into during the previous year does not exceed a sum of one hundred crore rupees; or (ii) not less than 18 per cent.....
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....rrency as on 30th September of the relevant previous year plus, - (a) If amount of loan advanced to the associated enterprise including loans to all associated enterprises does not exceed a sum equivalent to two hundred and fifty crore Indian rupees in the aggregate as on 31st March of the relevant previous year: (i) 150 basis points, where the associated enterprise has a credit rating of AAA, AA+, AA, AA-, A+, A, A- or equivalent; (ii) 300 basis points, where the associated enterprise has credit rating of BBB+, BBB, BBB- or equivalent; (iii) 400 basis points, where the associated enterprise has a credit rating of BB+, BB, BB-, B+, B, B-, C+, C, C-, D or equivalent or where the credit rating of the associated enterprise is not available; (b) If amount of loan advanced to the associated enterprise including loans to all associated enterprises exceeds a sum equivalent to two hundred and fifty crore Indian rupees in the aggregate as on 31st March of the relevant previous year: (i) 150 basis points, where the associated enterprise has a credit rating of AAA, AA+, AA, AA-, A+, A, A- or equivalent; (ii) 300 basis points, where the associated enterprise has credit rating of BB....
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.... for allocation of costs to the assessee by the overseas associated enterprise, is certified by an accountant.] 15[Explanation.- For the purposes of this sub-rule,- (a) "reference rate" means,- (i) for US dollar, 6-month Term Secured Overnight Financing rate (SOFR), currently administered by Chicago Mercantile Exchange (CME), as increased by 45 basis points; (ii) for Euro, 6-month Euro Inter Bank Offered Rate (EURIBOR), currently administered by European Money Markets Institute; (iii) for UK Pound Sterling, 6-month Term Sterling Overnight Index Average (SONIA), currently administered by ICE Benchmark Administration/Refinitiv, as increased by 30 basis points; (iv) for Japanese Yen, 6-month Tokyo Term Risk Free Rate (TORF), currently benchmarked by QUICK Benchmarks Inc, as increased by 10 basis points; (v) for Australian dollar, 6-month Bank Bill Swap Rates (BBSW) currently administered by Australian Securities Exchange; and (vi) for Singapore dollar, 6-month Compounded Singapore Overnight Rate Average (SORA), currently administered by Monetary Authority of Singapore, as increased by 45 basis points; (b) "credit rating" means the credit rating assigned to the associate....
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....ed vide Notification No. 66/2022 dated 17-06-2022 w.e.f. 01-04-2022 before it was read as, "7[assessment years 2020-21 and 2021-22]" 9. Substituted vide Notification No. 58/2023 dated 09-08-2023 w.e.f. 01-04-2023 before it was read as, "8[assessment years 2020-21, 2021-22 and 2022-23]" 10. Omitted vide Notification No. 104/2023 dated 19-12-2023 w.e.f. 01-04-2024 before it was read as, "CRISIL" 11. Omitted vide Notification No. 104/2023 dated 19-12-2023 w.e.f. 01-04-2024 before it was read as, "CRISIL" 12. Omitted vide Notification No. 104/2023 dated 19-12-2023 w.e.f. 01-04-2024 before it was read as, "CRISIL" 13. Omitted vide Notification No. 104/2023 dated 19-12-2023 w.e.f. 01-04-2024 before it was read as, "CRISIL" 14. Substituted vide Notification No. 104/2023 dated 19-12-2023 w.e.f. 01-04-2024 before it was read as, "5. Advancing of intra-group loans referred to in item (iv) of rule 10TC where the amount of loan is denominated in foreign currency. The interest rate declared in relation to the eligible international transaction is not less than the six-month London Inter-Bank Offer Rate of the relevant foreign currency as on 30th September of t....