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Income-tax Rules, 2026 | Rule 97 of 333

Rule 97 - Safe harbour for eligible specified domestic transaction

Reviewed by CA Nikhil Gupta · Last reviewed 29 August 2026

Local extract available Legacy mapping: 10TH-10THD

97Rule number
1621Local text characters
0Linked Forms
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

Safe harbour for eligible specified domestic transaction. 97. (1) The transfer price declared by an eligible assessee in respect of an eligible specified domestic transaction for a tax year shall be accepted by the income-tax authorities, if— (a) the option exercised by the said assessee is treated to be validly exercised under rule 98; and (b) it is in accordance with the circumstances as specified in sub-rule (2). (2) The circumstances referred to in sub-rule (1) are, for the eligible specified domestic transaction concerned: 1. Supply of electricity, transmission of electricity, or wheeling of electricity — the tariff is determined, or the methodology for determination of the tariff is approved, by the Appropriate Commission in accordance with the Electricity Act, 2003 (36 of 2003). 2. Purchase of milk or milk products — the price of milk or milk products is determined at a rate fixed on the basis of the quality of milk (fat content and Solid Not Fat (SNF) content), and (a) the said rate is irrespective of (i) the quantity of milk procured; or (ii) the percentage of shares held by the members in the co-operative society; or (iii) the voting power held by the members in the society; and (b) such rates are routinely declared by the co-operative society in a transparent manner and are available in the public domain. (3) No comparability adjustment and allowance under section 165(3)(a)(ii) shall be made to transfer prices accepted under sub-rule (1). (4) The provisions of sections 171 and 172 shall apply to specified domestic transactions regardless of the exercise of the safe harbour option.

Local extract SHA-256: 039fdca93f9af11700f0f7db1a178632700c9784b8c4bd35c4652c6f03b7ae3d. This hash authenticates the local extract only; it does not certify that every amendment, table or Gazette footnote has been consolidated.

Rule map

Related sections

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Finin2min implementation framework

Trigger and scope

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Evidence and control

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Consequence

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Transaction application

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Authority, consent and execution

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Evidence and retention checklist

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Limitation, forum and remedies

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Cross-law overlays

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Finin2min Q&A

Is this page the notified Rule?

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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