Rule 129 prescribes notice and forms for Section 274 reference, detailing objections, tax benefit basis, and Commissioner’s satisfaction before invoking Chapter XI provisions.
Rules 127 and 128 of the Draft Income-tax Rules, 2026 restrict GAAR impact to the tainted part of an arrangement and exempt cases below ₹3 crore tax benefit and specified FII investments.
Draft Rule 126 of the Income-tax Rules, 2026 limits eligible activities of IFSC-based Finance Companies and mandates foreign currency interest payments to qualify under section 177.
Draft Rule 125 of the Income-tax Rules, 2026 mandates Form 61 authorization filing and extensive ownership disclosures for transactions with notified jurisdictional areas, requiring eight-year record retention to strengthen compliance.
Draft Rule 124 of the Income-tax Rules, 2026 sets out the procedure, timelines, and forms for furnishing country-by-country reports under section 511, triggered by a ₹6,400 crore consolidated revenue threshold.
Rule 122 of the Draft Income-tax Rules, 2026 requires the foreign associated enterprise to initiate an APA process before India begins bilateral or multilateral negotiations, ensuring coordinated and mutually acceptable transfer pricing agreements.
Draft Rule 123 of the Income-tax Rules, 2026 requires constituent entities of large international groups to maintain and furnish extensive documentation when revenue and transaction thresholds are exceeded.
Rule 121 of the Draft Income-tax Rules, 2026 lays down a structured mutual agreement procedure with defined timelines and safeguards, ensuring transparent resolution of cross-border tax disputes without reducing declared income in India.
Rule 114 of the Draft Income-tax Rules, 2026 requires the Transfer Pricing Officer to conduct annual compliance audits of APAs, ensuring adherence to agreed terms and critical assumptions.
Rules 112 and 113 of the Draft Income-tax Rules, 2026 allow amendment of APA applications before finalisation and mandate timely filing of annual compliance reports to ensure continued adherence.
