RULE 93 INCOME-TAX RULES 2026 Mutual agreement procedure not to apply where Safe harbour for international transactions is accepted.

Mutual agreement procedure not to apply where Safe harbour for international transactions is accepted.

93. Where transfer price in relation to an eligible international transaction, declared by an eligible assessee, is accepted by the income-tax authorities under section 167, the assessee shall not be entitled to invoke mutual agreement procedure under an agreement for avoidance of double taxation entered into with a country or specified territory outside India, as referred to under section 159.