Income-tax Rules, 2026 | Rule 102 of 333

Rule 102 - Mutual agreement procedure not to apply where income-attribution safe harbour is exercised

Reviewed by CA Nikhil Gupta · Last reviewed 29 August 2026

Local extract available Legacy mapping: 10TI-10TIC

102Rule number

500Local text characters

0Linked Forms

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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

Mutual agreement procedure not to apply where safe harbour for income attribution in case of income from business and profession is exercised. 102. The assessee shall not be entitled to invoke mutual agreement procedure under an agreement for avoidance of double taxation as referred to in section 159 in relation to an eligible business, if the assessee has exercised the option for safe harbour under rule 101 in respect of such business and such option is not declared invalid under the said rule.

Local extract SHA-256: 94d0a448066dc35902724c922ca5da575fd3051483c097447084fd73d2d6df31. 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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Consequence

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Finin2min Q&A

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What should be verified immediately before use?

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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)