RULE 88 INCOME-TAX RULES 2026
Eligible international transactions for safe harbour.
88. An “eligible international transaction” means an international transaction between the eligible assessee and its associated enterprise, one of which is necessarily a non-resident, and which comprises of—
| (a) | | provision of information technology services consisting of any one or more of the following:— |
| (i) | | provision of software development services; or |
| (ii) | | provision of information technology enabled services; or |
| (iii) | | provision of knowledge process outsourcing services; or |
| (iv) | | provision of contract research and development services wholly or partly relating to software development; or |
| (b) | | advance of intra-group loan; or |
| (c) | | provision of corporate guarantee, where the amount guaranteed, — |
| (i) | | does not exceed one hundred crore rupees; or |
| (ii) | | exceeds one hundred crore rupees, and the credit rating of the associated enterprise, done by an agency registered with the Securities and Exchange Board of India, is of the adequate to highest safety; or |
| (d) | | provision of contract research and development services, wholly or partly, relating to generic pharmaceutical drugs; or |
| (e) | | manufacture and export of core auto components; or |
| (f) | | manufacture and export of non-core auto components; or |
| (g) | | receipt of low value-adding intra-group services from one or more members of its group; or |
| (h) | | provision of the data centre services. |