Rule 93 bars an assessee whose declared transfer price is accepted under the safe harbour in section 167 from invoking the mutual agreement procedure under a double taxation agreement.
93
Rules 2026 · Rule 93
Mutual agreement procedure not to apply where Safe harbour for international transactions is accepted
Rules 77-130
The rule. Where the transfer price of an eligible international transaction declared by an eligible assessee is accepted by the income-tax authorities under section 167, the assessee is not entitled to invoke the mutual agreement procedure under an agreement for avoidance of double taxation with a country or specified territory outside India, as referred to in section 159.