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Rule 102

Mutual agreement procedure not to apply where safe harbour for income attribution in case of income from business and profession is exercised

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.

Source: Income-tax Rules, 2026, notified by the CBDT vide G.S.R. 198(E) dated 20 March 2026. For reference only – please verify with the official Gazette.

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