Rule 102 bars an assessee that has exercised the income-attribution safe harbour under rule 101, and whose option is not declared invalid, from invoking the mutual agreement procedure under a double taxation agreement for the eligible business.
102
Rules 2026 · Rule 102
Mutual agreement procedure not to apply where safe harbour for income attribution in case of income from business and profession is exercised
Rules 77-130
The rule. The assessee is not entitled to invoke the mutual agreement procedure under an agreement for avoidance of double taxation (section 159) in relation to an eligible business, if it has exercised the safe harbour option under rule 101 for that business and the option is not declared invalid.