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Rule 253

Nature of business relationship

For the purposes of section 515(3)(b)(ii)(H), the term "business relationship" shall be construed as any transaction entered into for a commercial purpose, other than —

(A) commercial transactions which are in the nature of professional services permitted to be provided by an auditor or audit firm under the Act and the Chartered Accountants Act, 1949 (38 of 1949) and the rules or regulations made under the said Acts; and

(B) commercial transactions that are conducted in the normal course of business of the company at a fair market price, such as the sale of products or services to the auditor as a customer in the regular operation of business, by companies involved in telecommunications, airlines, hospitals, hotels, and other similar industries.

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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