Indian Safe Harbour Regime Revamped: Draft Income-tax Rules, 2026
Safe Harbour Rules ('SHR') were first introduced in Indian Transfer Pricing (‘TP’) regime by the Central Board of Direct Taxes ('CBDT') in September 2013 under Section 92CB of the Income-tax Act, 1961 (‘the Act’). Designed as a litigation-reduction mechanism, SHRs allow tax authorities to accept a taxpayer's declared transfer price for specified international transactions without detailed scrutiny, provided predefined conditions are satisfied.
