Income-tax Rules, 2026

Rule 93Mutual agreement procedure not to apply where safe harbour for international transactions is accepted

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

Where transfer price in relation to an eligible international transaction, declared by an eligible assessee, is accepted by the income-tax authorities under section 167, the assessee shall not be entitled to invoke mutual agreement procedure under an agreement for avoidance of double taxation entered into with a country or specified territory outside India, as referred to under section 159.

This rule refers to

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

§ 167 Power of Board to make safe harbour rules

Referenced by

Rule 86 Definitions for safe harbour rules for international transactions