The Central Board of Direct Taxes (CBDT) vide notification number G.S.R. 595(E) issued on 9th August 2023 has notified the Income-tax (Fifteenth Amendment) Rules, 2023 and the extension of safe harbour rules mentioned in the Rule 10TD of the Income Tax Rules, 1962 for accepting the transfer pricing declared by the assessee.
Utilising the authority granted by section 295 in conjunction with subsection (2) of section 92CB of the Income-tax Act, 1961, the CBDT has introduced amendments to the safe harbour rules.
The amendment is called the Income-tax (Fifteenth Amendment) Rules, 2023 and deemed to have come into force on 1st April 2023. Section 92CB empowers the board (CBDT) to make safe harbour rules. The determination of arm’s length price under section 92C or section 92CA shall be subject to safe harbour rules.
According to the new amendment “In the Income-tax Rules, 1962, in rule 10TD, in sub-rule (3B), for the words and figures “assessment years 2020- 21, 2021-22 and 2022-23”, the words and figures “assessment years 2020-21, 2021-22, 2022-23 and 2023-24” shall be substituted.”
The effect of the notification is that the amendment is effective from 1st day of April, 2023 and applies to assessment year 2023-24 relevant to previous year 2022-23. Accordingly, it is hereby certified that no person is being adversely affected by giving retrospective effect to these rules.
Subscribe Taxscan Premium to view the JudgmentSupport our journalism by subscribing to Taxscan premium. Follow us on Telegram for quick updates
