Income-tax Rules, 2026 | Rule 88 of 333

Rule 88 - Eligible international transactions for safe harbour

Reviewed by CA Nikhil Gupta · Last reviewed 29 August 2026

Local extract available Legacy mapping: 10TA-10TG

88Rule number

1372Local text characters

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Source and status control

Primary authority: Notification No. 22/2026 / G.S.R. 198(E)

Currentness control: Base Rules effective 1 April 2026. Check later amendments, corrigenda and portal implementation before action.

Local statutory extract - official source controls

Rule text held in the production corpus

Eligible international transactions for safe harbour. 88. An "eligible international transaction" means an international transaction between the eligible assessee and its associated enterprise, one of which is necessarily a non-resident, and which comprises of— (a) provision of information technology services consisting of any one or more of: (i) provision of software development services; or (ii) provision of information technology enabled services; or (iii) provision of knowledge process outsourcing services; or (iv) provision of contract research and development services wholly or partly relating to software development; or (b) advance of intra-group loan; or (c) provision of corporate guarantee, where the amount guaranteed— (i) does not exceed one hundred crore rupees; or (ii) exceeds one hundred crore rupees, and the credit rating of the associated enterprise, done by an agency registered with the Securities and Exchange Board of India, is of the adequate to highest safety; or (d) provision of contract research and development services, wholly or partly, relating to generic pharmaceutical drugs; or (e) manufacture and export of core auto components; or (f) manufacture and export of non-core auto components; or (g) receipt of low value-adding intra-group services from one or more members of its group; or (h) provision of the data centre services.

Local extract SHA-256: 5108b1f1dd30ae84c05090fc51af428ab0894c00221a37fca4d7532394881e80. This hash authenticates the local extract only; it does not certify that every amendment, table or Gazette footnote has been consolidated.

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Related sections

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Related Forms

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Finin2min implementation framework

Trigger and scope

Determine whether the facts fall within the Rule heading and linked section. Verify commencement and the tax year involved.

Evidence and control

Preserve the return, statement, report, certificate, computation, source records and acknowledgement relevant to this Rule.

Consequence

Non-compliance may affect computation, exemption, deduction, procedural validity, reporting, recovery, appeal or penalty depending on the governing section.

Transaction application

Identify the actor, event date, governing tax year or reporting period, authority, document version and every cumulative condition. Record why each limb is satisfied, disputed or not applicable.

Authority, consent and execution

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Evidence and retention checklist

Retain source data, approvals, computations, correspondence, filing acknowledgement, payment record, amended filing history and the version of the governing instrument used.

Limitation, forum and remedies

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Cross-law overlays

Check the Income-tax Act, 2025, transition rules, relevant Schedule, tax treaty, Companies Act, GST, FEMA and accounting treatment where the transaction crosses regimes.

Finin2min Q&A

Is this page the notified Rule?

It contains a local statutory extract, but the linked official source and later amendments control.

What should be verified immediately before use?

Effective date, amendment history, forms or utilities, filing channel, authentication method, due date, fees, transition from the 1962 Rules and any judicial interpretation.

Source and review trail

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Official starting point: www.incometaxindia.gov.in

Page source links

Notification No. 22/2026 / G.S.R. 198(E)