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of <h1>Tax Authority Gains Power to Set Safe Harbour Rules for Cross-Border Transactions Under Clause 167 Income Tax Bill</h1> Legal Analysis Summary:The text analyzes Clause 167 of the Income Tax Bill, 2025, which empowers the tax authority to establish safe harbour rules for determining arm's length pricing and deemed income in cross-border transactions. The provision aims to reduce litigation, simplify compliance, and provide tax certainty. Compared to the existing Section 92CB, the new clause potentially expands the scope of safe harbour rules, offering mandatory acceptance of taxpayer-declared prices under specified conditions. The legislative approach seeks to enhance predictability in international taxation while maintaining flexibility for future regulatory adaptations.
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