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Draft Income Tax Rule 89 – Safe harbour for eligible international transactions

February 28, 2026 2871 Views 0 comment Print

Rule 89 of the Draft Income-tax Rules, 2026 prescribes fixed profit margins, interest spreads, and transaction limits for eligible international transactions to secure automatic acceptance of transfer prices, reducing litigation and compliance uncertainty.

Draft Income Tax Rule 88 – Eligible international transactions for safe harbour

February 28, 2026 396 Views 0 comment Print

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 Income Tax Rule 87 – Eligible assessee for safe harbour rules for international transactions

February 28, 2026 522 Views 0 comment Print

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.

Draft Income Tax Rules 85 and 86: Accountant’s Report under Section 172 and Safe Harbour Definitions for International Transactions

February 28, 2026 696 Views 0 comment Print

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 Income Tax Rule 84 – Information and documents to be kept and maintained under section 171(1)(a)

February 28, 2026 447 Views 0 comment Print

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 Income Tax Rule 83 – Time Limit for Repatriation under Section 170(2) and Interest Computation under Section 170(4) on Secondary Adjustments

February 28, 2026 369 Views 0 comment Print

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.

Draft Income Tax Rule 82 – Exercise of option for determination of Arm’s length price for multiple years in a single proceeding

February 28, 2026 381 Views 0 comment Print

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.

Draft Income Tax Rule 80 – Most appropriate method

February 28, 2026 219 Views 0 comment Print

Draft Rule 80 prescribes criteria for selecting the most appropriate transfer pricing method based on transaction nature, comparability, data reliability, and functional analysis.

Draft Income Tax Rule 79 – Determination of arm’s length price under section 165

February 28, 2026 297 Views 0 comment Print

Draft Rule 79 sets out recognized methods and comparability criteria for determining arm’s length price under section 165, mandating use of the most appropriate method and current-year data for accurate benchmarking.

Draft Income Tax Rules 77 and 78 – Meaning of Expressions and Other Method for Determining Arms Length Price

February 28, 2026 297 Views 0 comment Print

Draft Rules 77 and 78 clarify essential transfer pricing definitions and allow an alternative comparability-based method for determining arms length price. The provisions expand scope while enabling practical pricing based on similar uncontrolled transactions.

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