Income-tax Rules, 2026

Rule 102Mutual agreement procedure not to apply where safe harbour for income attribution in case of income from business and profession is exercised

Income-tax Rules, 2026 · G.S.R. 198(E), dated 20-03-2026

The assessee shall not be entitled to invoke mutual agreement procedure under an agreement for avoidance of double taxation as referred to in section 159 in relation to an eligible business, if the assessee has exercised the option for safe harbour under rule 101 in respect of such business and such option is not declared invalid under the said rule.

This rule refers to

Rule 101 Procedure governing safe harbour rules for income attribution in case of income from business and profession

§ 159 Agreement with foreign countries or specified territories and adoption by Central Government of agreement between specified associations for double taxation relief

Referenced by

Rule 99 Definitions for safe harbour rules for income attribution in case of income from business and profession