Pursuant to the Safe Harbour Rules in Rules 10TA to 10TG, the CBDT has issued a letter dated 20.12.2013 in which it has laid down important directives and clarifications on the manner in which the Safe Harbour Rules are meant to be implemented.
“In cases where an 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 carried out without regard to the safe harbour rates or margins,” said a CBDT letter to chief commissioners.
