Safe harbour for eligible international transactions

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....e Sl.No. Eligible International Transaction Circumstances A B C 1. Provision of information technology services. The operating profit margin declared by the eligible assessee from the eligible international transaction in relation to operating expense incurred is not less than 15.5%, where the aggregate operating revenue of such transaction entered into during the tax year does not exceed a sum of two thousand crore rupees. 2. Advancing of intra-group loans where the amount of loan is denominated in Indian Rupees (rupees). The interest rate declared in relation to the eligible international transaction entered into during the tax year is not less than the one-year marginal cost of funds lending rate of St....

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.... (i) 150 basis points, where the associated enterprise has a credit rating of AAA, AA+, AA, AA-, A+, A, A- or equivalent; or (ii) 300 basis points, where the associated enterprise has credit rating of BBB+, BBB, BBB- or equivalent; or (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 rupees (Indian rupees) in the aggregate as on the 31st March of the relevant tax year, - (i) 150 basis poi....

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....xport of noncore auto components. The operating profit margin declared by the eligible assessee from the eligible international transaction entered into during the tax year in relation to operating expense is not less than 8.5%. 8. Receipt of low value-adding intragroup services. The aggregate amount of the low value adding intra-group services during the tax year, including a mark-up not exceeding 5%, does not exceed a sum of ten crore rupees, and the method of cost pooling, the exclusion of shareholder costs and duplicate costs from the cost pool and the reasonableness of the allocation keys used for allocation of costs to the assessee by the overseas associated enterprise, is certified by an accountant. 9. Provision of ....