RULE 105 INCOME-TAX RULES 2026
Pre-filing consultation.
105. (1) An eligible person may make an application in Form No. 50 to the Principal Chief Commissioner of Income-tax (International Taxation) for a pre-filing consultation.
(2) On receipt of the application, the team shall hold pre-filing consultation with the eligible person who has applied under sub-rule (1).
(3) The competent authority of India or his representative shall be associated in pre-filing consultation involving bilateral or multilateral agreement.
(4) The pre-filing consultation shall, among other things,—
| (a) | determine the scope of the agreement; | |
| (b) | identify transfer pricing issues; | |
| (c) | determine the suitability of international transaction for the agreement; and | |
| (d) | discuss broad terms of the agreement. |
(5) The pre-filing consultation shall—
| (a) | neither bind the Board or the eligible person who has applied under sub-rule (1) to enter into an agreement or initiate the agreement process; | |
| (b) | nor be deemed to mean that the person has applied for entering into an agreement. |
(6) The provisions of this rule shall not apply in the case of renewal of the agreement.