TMI BlogSafe HarbourX X X X Extracts X X X X X X X X Extracts X X X X ..... in relation to operating expense incurred is - (i) not less than 20 per cent., where the aggregate value of such transactions entered into during the previous year does not exceed a sum of five hundred crore rupees; or (ii) not less than 22 per cent., where the aggregate value of such transactions entered into during the previous year exceeds a sum of five hundred crore rupees. 2. Provision of information technology enabled services referred to in item (ii) of rule 10TC. The operating profit margin declared by the eligible assessee from the eligible international transaction in relation to operating expense is - (i) not less than 20 per cent., where the aggregate value of such transactions entered into during the previous year does not exceed a sum of five hundred crore rupees; or (ii) not less than 22 per cent., where the aggregate value of such transactions entered into during the previous year exceeds a sum of five hundred crore rupees. 3. Provision of knowledge process outsourcing services referred to in item (iii) of rule 10TC. The operating profit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n item (viii) of rule 10TC. The operating profit margin declared by the eligible assessee from the eligible international transaction in relation to operating expense is not less than 12 per cent.. 11. Manufacture and export of non- core auto components referred to in item (ix) of rule 10TC. The operating profit margin declared by the eligible assessee from the eligible international transaction in relation to operating expense is not less than 8.5 per cent.. 3 [(2A) The circumstances referred to in sub-rule (1) in respect of the eligible international transaction specified in column (2) of the Table below shall be as specified in the corresponding entry in column (3) of the said Table:- Sl. No. Eligible International Transaction Circumstances (1) (2) (3) 1. Provision of software development services referred to in item (i) of rule 10TC. The operating profit margin declared by the eligible assessee from the eligible international transactio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (ii) 325 basis points, where the associated enterprise has 11 [****] credit rating of BBB-, BBB or BBB+ or its equivalent; (iii) 475 basis points, where the associated enterprise has 12 [****] credit rating between BB to B or its equivalent; (iv) 625 basis points, where the associated enterprise has 13 [****] credit rating between C to D or its equivalent; or (v) 425 basis points, where credit rating of the associated enterprise is not available and the amount of loan advanced to the associated enterprise including loans to all associated enterprises in Indian Rupees does not exceed a sum of one hundred crore rupees in the aggregate as on 31st March of the relevant previous year. 14 [ 5. Advancing of intra-group loans referred to in clause (iv) of rule 10TC where the amount of loan is denominated in foreign currency. The interest rate declared in relation to the eligible international transaction is not less than the reference rate of the relevant foreign currency as on 30th September of the relevant previous year plus, - (a) If amount of loan advanced to the associated enterprise including loans to all ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of rule 10TC. The operating profit margin declared by the eligible assessee from the eligible international transaction in relation to operating expense incurred is not less than 24 per cent., where the value of the international transaction does not exceed a sum of two hundred crore rupees. 9. Manufacture and export of core auto components referred to in item (viii) of rule 10TC . The operating profit margin declared by the eligible assessee from the eligible international transaction in relation to operating expense is not less than 12 per cent. 10. Manufacture and export of non-core auto components referred to in item (ix) of rule 10TC . The operating profit margin declared by the eligible assessee from the eligible international transaction in relation to operating expense is not less than 8.5 per cent. 11. Receipt of low value-adding intra-group services in item (x) of rule 10TC. The entire value of the international transaction, including a mark-up not exceeding 5 per cent., does not exceed a sum of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee shall have the right to choose the option which is most beneficial to him.] 6 [ (3B) The provisions of sub-rules (1) and (2A) shall apply for the 9 [ assessment years 2020-21, 2021-22, 2022-23 and 2023-24 ]] (4) No comparability adjustment and allowance under the second proviso to sub-section of section 92C shall be made to the transfer price declared by the eligible assessee and accepted under sub-rules (1) and (2) 5 [or, as the case may be, (2A) ] above. (5) The provisions of sections 92D and 92E in respect of an international transaction shall apply irrespective of the fact that the assessee exercises his option for safe harbour in respect of such transaction.] ------------------- Notes :- 1. Inserted vide Notification No. 73/2013 September 18, 2013 2. Inserted vide Not. 46/2017 - Dated 7-6-2017 w.e.f. 1st day of April, 2017 3. Inserted vide Not. 46/2017 - Dated 7-6-2017 w.e.f. 1st day of April, 2017 4. Inserted vide Not. 46/2017 - Dated 7-6-2017 w.e.f. 1st day of April, 2017 5. Inserted vide Not. 46/2017 - Dated 7-6-2017 w.e.f. 1st day of April, 2017 6. Inserted vide NOTIFICATION NO. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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