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.
Major Amendments Introduced
Lithium-Ion Batteries for EVs: A significant inclusion in Rule 10TA now recognizes lithium-ion b
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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.