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Rule 120

Miscellaneous

(1) Mere filing of an application for an agreement under these rules shall not prevent the operation of Chapter X of the Act for determination of arms' length price under that Chapter till the agreement is entered into.

(2) The negotiation between the competent authority of India and the competent authority of the other country or countries, in case of bilateral or multilateral agreement, shall be carried out in accordance with the provisions of the tax treaty between India and the other country or countries.

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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