Notification No.: 124/2024
Notification Date: 29th November 2024
Relevant Act / Rule: Income Tax Act, 1961
The Central Board of Direct Taxes (CBDT) has notified the Income-Tax (Tenth Amendment) Rules, 2024, which include the following changes:
1. Substitution in Rule 10TD(3B), replacing the assessment years 2020-21, 2021-22, 2022-23, and 2023-24 with 2020-21, 2021-22, 2022-23, 2023-24, and 2024-25.
2. Insertion of a new Rule DCA (Safe Harbour Rules for income referred to in Section 9(1)(i) chargeable to tax under the head “Profits and gains of business or profession”) after Rule 10THD and Rules 10TIA (Safe Harbour), 10TIB (Procedure), and 10TIC (Mutual Agreement Procedure not to apply).
3. The amendment introduces safe harbour provisions for foreign companies in diamond mining and raw diamond sales in special zones. To qualify, businesses must have a minimum 4% profit margin on gross receipts, eliminating the need for transfer pricing assessments. The rules also restrict deductions, loss set-offs, and depreciation claims to simplify compliance. These provisions exclude businesses from invoking mutual agreement procedures under double taxation avoidance agreements.
4. Insertion of a new Form No. 3CEFB, following Appendix-II, for the application to opt for safe harbour for income referred to in clause (i) of sub-section (1) of Section 9, chargeable to tax under the head “Profits and gains of business or profession.
Disclaimer: The information contained in this Article is intended solely for personal non-commercial use of the user who accepts full responsibility of its use. The information in the article is general in nature and should not be considered to be legal, tax, accounting, consulting or any other professional advice. We make no representation or warranty of any kind, express or implied regarding the accuracy, adequacy, reliability or completeness of any information on our page/article.