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India Extends Scope of Transfer Pricing Safe Harbour Rules and Increases Maximum Transaction Value for Certain Services

28 March 2025

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Approved Changes

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India

India's Central Board of Direct Taxes has announced the publication of Notification No. 21/2025 of 25 March 2025, which contains the Income-tax (Sixth Amendment) Rules 2025. This includes three main amendments to the Safe Harbour Rules for International Transactions in the Income Tax Rules 1962. The first amendment is to Rule 10TA (Definitions) to add "lithium ion batteries for use in electric or hybrid electric vehicles" as a core auto component benefiting from the safe harbour rules. The second amendment is to Rule 10TD (Safe Harbour), providing that the maximum international transaction value eligible for the safe harbour is increased...