Pre-filing Consultation.
10H. (1) Any person proposing to enter into an agreement under these rules may, by an application in writing, make a request for a pre-filing consultation.
(2) The request for pre-filing consultation may be made in Form No. 3 CEC to the Director General of Income-tax (International Taxation).
(3) On receipt of the request in Form No. 3 CEC, the team may hold pre-filing consultation with the person referred to in rule 10G.
(4) The competent authority in India or his representative may be associated in pre-filing consultation involving bilateral or multilateral agreement.
(5) The pre-filing consultation may, among other things,-
(i) determine the scope of the agreement;
(ii) identify transfer pricing issues;
(iii) determine the suitability of international transaction for the agreement;
(iv) discuss broad terms of the agreement.
(6) The pre-filing consultation may-
(i) not bind the Board or the person to enter into an agreement or initiate the agreement process;
(ii) not be deemed to mean that the person has applied for entering into an agreement. |