Draft Rule 109 of the Income-tax Rules, 2026 lays down a detailed, time-bound procedure for processing Advance Pricing Agreement applications, including consultation, enquiry, agreement finalisation, and conditions for closure without refund.
Draft Rule 108 of the Income-tax Rules, 2026 establishes a structured deficiency review process for Advance Pricing Agreement applications, allowing correction of defects and providing for refund of fees if the application is rejected.
Draft Rules 103 to 107 of the Income-tax Rules, 2026 define key expressions, eligibility, consultation, application, and withdrawal procedures for Advance Pricing Agreements to provide structured and transparent APA implementation.
Draft Rules 101 and 102 of the Income-tax Rules, 2026 prescribe the procedure for opting safe harbour in income attribution cases and clarify that taxpayers cannot invoke Mutual Agreement Procedure once the option is validly exercised.
Draft Rule 88 of the Income-tax Rules, 2026 clearly identifies the categories of international transactions that qualify for safe harbour, helping taxpayers determine eligibility and reduce transfer pricing disputes.
Draft Rule 87 of the Income-tax Rules, 2026 specifies categories of eligible assessees and lays down stringent low-risk conditions to ensure certainty and simplified compliance under safe harbour transfer pricing rules.
Rules 85 and 86 of the Draft Income-tax Rules, 2026 mandate accountant certification for international and specified domestic transactions and define key terms for safe harbour rules. The provisions aim to standardize reporting timelines and clarify eligibility criteria for transfer pricing compliance.
Draft Rule 84 of the Income-tax Rules, 2026 requires taxpayers entering international or specified domestic transactions to maintain extensive contemporaneous documentation to substantiate arm’s length pricing and avoid disputes.
Draft Rule 83 of the Income-tax Rules, 2026 mandates a 90-day repatriation deadline for excess money arising from secondary transfer pricing adjustments, failing which imputed interest is levied at prescribed benchmark rates.
Rule 82 allows assessees to determine arm’s length price for two additional consecutive years in a single transfer pricing proceeding, provided strict similarity and compliance conditions are satisfied. The key takeaway: the option is available only where transactions, methods, and functional profiles remain materially unchanged.
