TMI BlogU/S 92CB - SAFE HARBOUR RULES - IMMEDIATE ACTION REQUIRED INCLUDING REPORT FROM ALL ASSESSING OFFICERS (AOs) ON DETAILS OF FORM 3CEFA RECEIVED BY THEMX X X X Extracts X X X X X X X X Extracts X X X X ..... eld a video conference with CCIT(CCAs) New Delhi, Mumbai, Kolkata, Bangalore, Ahmedabad, Hyderabad, Chennai, Pune, Chandigarh and DGIT (International Taxation) on 17th December at 10.30 am. 2. The following issues were discussed during the video conference: Chairperson, CBDT provided a summary of Rules 10TA to 10TG relating to Safe Harbour prescribed under section 92CB of the Income-t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... taken within this period by the AO, the Safe Harbour option will be considered as having been accepted, and may then remain valid for 5 years. JS-FT TR-I clarified that for minor defects in Form 3CEFA the AO can provide an opportunity to the taxpayer to rectify the same. However, the statutory time limit of 2 months provided in Rule 10TE (14)(i) cannot be exceeded by the AO under any cir ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sized that as stated clearly in the Rules, the Safe Harbour rates or margins specified therein are not to be considered as a benchmark by the AO or TPO in cases not covered by the Safe Harbour Rules. In cases where assessee has not opted for Safe Harbour or the option has not been found to be valid, and a regular transfer pricing audit is considered necessary, such transfer pricing audit will be c ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
