Rule 104

Persons eligible to apply

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A person shall be eligible to enter into an agreement under these rules, if he —

(a) has undertaken an international transaction; or

(b) is contemplating to undertake an international transaction.

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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.