India’s Central Board of Direct Taxes (CBDT) has released Notification No. 124/2024 outlining the Income Tax (Tenth Amendment) Rules, 2024 on 29 November 2024.
According to the amendment, the transfer pricing safe harbor rules under Rule 10TD of the Income Tax Rules, 1962, have been extended to the assessment year 2024-25. This follows after the extension of the FY 2023-24 assessment year, which was extended for 2022-23.
The safe harbor rules cover software and IT development and related services, specific R&D services, knowledge process outsourcing, corporate guarantees, intra-group loans, auto component manufacturing and export, and low-value intra-group services.
The extension went into force on 1 April 2024.
New transfer pricing safe harbor for raw diamonds sales introduced
The amended rules introduce a new transfer pricing safe harbor for selling raw diamonds within designated special zones, which went into force immediately after the publication of the circular.
Tax return deadline for transfer pricing cases extended
The CBDT has also extended the deadline for filing annual tax returns for the 2024-25 assessment year (for the 2023-24 financial year) for taxpayers reporting international and specified domestic transactions under transfer pricing provisions.
The new deadline is 15 December 2024, extended from 30 November 2024.
The announcement was made in Circular No. 18/2024, issued on 30 November 2024.
