CBDT Notifies Amendments in Income-Tax Rules to Broaden Safe Harbour Scope



Quick Summary
The Central Board of Direct Taxes (CBDT) has introduced significant amendments to the Income-Tax Rules, 1962, through Notification No. 21/2025. Key changes include the inclusion of lithium-ion batteries for electric vehicles under safe harbour provisions, a revision of safe harbour margins for international transactions to 3% in certain cases, and an extension of these provisions up to assessment year 2026-27. These updates aim to support the EV industry, provide greater certainty for multinational corporations, and offer a longer tax planning horizon for service providers.

CBDT Notifies Sixth Amendment to Income-Tax Rules, 2025

Key Highlights of Notification No. 21/2025

The Central Board of Direct Taxes (CBDT) has issued Notification No. 21/2025 on March 25, 2025, amending the Income-tax Rules, 1962. The Income-tax (Sixth Amendment) Rules, 2025 introduce key changes impacting transfer pricing, electric vehicles, and assessment years.

Income Tax Rules Amended: Safe Harbour Scope Broadened

Major Amendments Introduced

  • Lithium-Ion Batteries for EVs: A significant inclusion in Rule 10TA now recognizes lithium-ion batteries used in electric and hybrid vehicles under safe harbor provisions. This move aligns with India's push for sustainable mobility.
  • Revised Safe Harbor Margins: Under Rule 10TD, safe harbor margins for multiple international transactions have been revised, increasing the prescribed profit margins from 2% to 3% in several cases.
  • Extended Safe Harbor Period: Assessment years covered under Rule 10TD(3B) have been extended up to 2026-27, ensuring continued benefits for eligible taxpayers.
  • Clarity on Assessment Year Validity: A provision in Rule 10TE(2) now specifies that certain safe harbor benefits apply for one assessment year only, eliminating ambiguity.

Implications for Taxpayers & Businesses

  • Boost for EV Industry - Lithium-ion battery inclusion encourages investment in clean energy.
  • Increased Certainty for MNCs - Revised margins provide clarity in transfer pricing disputes.
  • Longer Tax Planning Horizon - Extension of safe harbor rules benefits IT, ITeS, and R&D service providers.

This notification is a crucial step toward enhancing tax compliance while supporting India's green energy and business-friendly policies.

Official copy of the notification has also been attached

FAQ :

The CBDT's notification aims to amend the Income-Tax Rules, 1962, to broaden the scope of safe harbour provisions, impacting transfer pricing, electric vehicles, and assessment years.

Lithium-ion batteries used in electric and hybrid vehicles have now been included under the safe harbour provisions, encouraging investment in sustainable mobility.

Yes, the safe harbour margins for several international transactions have been revised, with prescribed profit margins increasing from 2% to 3% in some instances.

The assessment years covered under Rule 10TD(3B) have been extended up to 2026-27, providing continued benefits for eligible taxpayers.

Yes, a new provision specifies that certain safe harbour benefits are applicable for one assessment year only, thereby removing any ambiguity.




News posted by

Finance news reporter covering taxation, GST, income tax, business compliance, and economy updates. I simplify complex financial topics into easy-to-understand articles for professionals, taxpayers, and business owners on leading finance and tax platforms.

Comments :


More »

Popular News





CCI Pro



Company
13 October 2026
Accountant

Zerdi & Co. Chartered Accountants

Pune

B.Com

View Details
Company
30 September 2026
Senior Accounts Executive

Codeboard Technology

Chennai

MBA

View Details
Company
19 September 2026
CA/Semi-CA/BCom

Pravin Sarvaiya

Mumbai

CA Inter

View Details
Company
08 October 2026
Accounts and Tax Associate

POOJA R TELI & CO

Pune

CA Inter

View Details
Company
08 October 2026
SALES TELECALLER

HIRE NOVA

Lucknow

Graduate (Any)

View Details
Company
ARTICLESHIP 08 October 2026
ARTICLE TRAINEE

S.B.G. & CO. CHARTERED ACCOUNTANTS

New Delhi

CA Inter

View Details
Company
06 October 2026
Assistant Manager - Audit and Compliance

Ravi K Jain & Co

Noida

Others

View Details
Company
14 October 2026
Accountant

Rize.farm

Bengaluru

B.Com

View Details