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Case law › Notifications › 2025 › Notification No. 21/2025 [F. No. 370142/6/2025-TPL] / GSR 193(E)
Notification 25 March 2025

Notification No. 21/2025 [F. No. 370142/6/2025-TPL] / GSR 193(E)

Ministry of Finance

What this is

Notification No. 21/2025 [F. No. 370142/6/2025-TPL] / GSR 193(E) was published on 25 March 2025. Its subject is Ministry of Finance.

This amends the Income-tax Rules. What it changes is the Rules, not the Act — and a rule can never take away what the section gives.

What it does

The Income-tax (Sixth Amendment) Rules, 2025 amend the safe harbour rules for international transactions. In rule 10TA, clause (b), a new sub-clause (iv) is inserted so that 'lithium ion batteries for use in electric or hybrid electric vehicles' are added to the list. In rule 10TD, sub-rule (2A), the Table is amended at serial numbers 1, 2, 3, 7 and 8 to substitute the word 'three' for the word 'two' in column (3), and sub-rule (3B) is widened from assessment years 2020-21 to 2024-25 to assessment years 2020-21 to 2026-27. In rule 10TE, sub-rule (2), the fourth proviso now reads with the words 'for one assessment year' inserted after 'rule 10TD'.

Who it reaches

The provisions it speaks to

Left, the provision of the Income-tax Act, 1961 as the instrument itself names it. Right, the section of the Income-tax Act, 2025 that the department’s own concordance maps it to — which is where the same ground is now covered.
Under the 1961 ActNow
s.3s.3
s.92CBs.167
s.295s.533

The instrument, as the Board published it

The department publishes this one only as a PDF, so the words below were read out of that PDF by machine. That reading can carry its own mistakes — a misread number, a broken line. Check the signed document before you rely on a figure in it.

MINISTRY OF FINANCE
(Department of Revenue)
(CENTRAL BOARD OF DIRECT TAXES)
NOTIFICATION
New Delhi, the 25th March, 2025
No. 21/2025
INCOME-TAX
G.S.R. 193(E).—In exercise of the powers conferred by section 295 read with sub-section (2) of section 92CB of the Income-tax Act, 1961 (43 of 1961), the Central Board of Direct Taxes hereby makes the following rules further to amend the Income-tax Rules, 1962, namely:___

1. (1) These rules may be called the Income-tax (Sixth Amendment) Rules, 2025.
(2) They shall come into force on the date of their publication in the Official Gazette.

2. In the Income-tax Rules, 1962,–
(a) in rule 10TA, in clause (b),–
I. in sub-clause (iii), at the end, the word ―or‖ shall be inserted;
II. after sub-clause (iii), the following sub-clause shall be inserted, namely:–
―(iv) lithium ion batteries for use in electric or hybrid electric vehicles.‖;

(b) in rule 10TD,—
I. in sub-rule (2A), in the Table,—
(A) in Sl.No. 1, in column number (3), in clause (ii), for the word ―two‖, the word ―three‖ shall be substituted;
(B) in Sl.No. 2, in column number (3), in clause (ii), for the word ―two‖, the word ―three‖ shall be substituted;
(C) in Sl.No. 3, in column number (3), in the opening portion, for the word ―two‖, the word ―three‖ shall be substituted;
(D) in Sl.No. 7, in column number (3), for the word ―two‖, the word ―three‖ shall be substituted;
(E) in Sl.No. 8, in column number (3), for the word ―two‖, the word ―three‖ shall be substituted;

II. in sub-rule (3B), for the words and figures ―assessment years 2020-21, 2021-22, 2022-23, 2023-24 and 2024-25‖, the words and figures ―assessment years 2020-21, 2021-22, 2022-23, 2023-24, 2024-25, 2025-26 and 2026-27‖ shall be substituted;

(c) in rule 10TE, in sub-rule (2), in the fourth proviso, after the word, figures and letters ―rule 10TD‖, the words ―for one assessment year‖ shall be inserted.

[F. No. 370142/6/2025-TPL]
THAKUR SINGH MAPWAL, Director

Note : The principal rules were published in the Gazette of India, Extraordinary, Part-II, section 3, sub-section (ii) vide number S.O. 969 (E) dated the 26th March, 1962 and were last amended vide notification number G.S.R. 145(E) dated the 24th February, 2025.

Uploaded by Dte. of Printing at Government of India Press, Ring Road, Mayapuri, New Delhi-110064
and Published by the Controller of Publications, Delhi-110054.

What it changes

The rule numbers are the 1962 Rules’ own, as the notification names them. The right-hand column is the department’s own mapping into the Income-tax Rules, 2026, which renumbered nearly everything.
Rule of the 1962 RulesNow, in the 2026 Rules
Rule 10TArule 86
Rule 10TDrule 89
Rule 10TErule 90

From when

The date of publication in the Official Gazette (25 March 2025).

What to watch

Where you meet it

In the option for safe harbour exercised under rule 10TE and in the transfer pricing officer's treatment of that option for assessment years up to 2026-27.

What it names

Rules it names. Rule 10TA, 10TD, 10TE of the Income-tax Rules, 1962. The 1962 Rules were replaced by the Income-tax Rules, 2026, which renumbered nearly everything: a rule number quoted here almost never means the same rule today.

On the same provision

Other instruments in this library that name the same provision of the 1961 Act. They are not necessarily still operative, and a later one may have replaced an earlier one without saying so.

← Notification No. 22/2025 [F.No. 370142/08/2025-TPL] / GSR 195(E)  ·  Notification No. 20/2025 [F.No. 225/33/2025/ITA-II] / SO 1241(E) →

What a notification is. A notification is made under a power the Act itself gives, and within that power it is law — unlike a circular, which only binds the department. Its reach is the reach of the enabling provision and no wider, and the date it carries decides from when it works.

Source: the Income Tax Department’s own published text — its page for this instrument.