Part DCA - Safe Harbour Rules for income referred to in clause (i) of sub-section (1) of section 9 chargeable to tax under the head (From Rule 10TI to Rule 10TIC)
Rule 44G - Application seeking to give effect to the terms of any agreement under clause (h) of sub-section (2) of section 295 and the procedure for giving effect to the decision under the Agreement.
Mutual agreement procedure under tax treaties governs cross-border dispute resolution, acceptance, and implementation of agreed outcomes. Rule 44G provides the mutual agreement procedure for implementing agreements between India and a foreign country or specified territory where an assessee claims that tax authority action is not in accordance with the agreement. A resident assessee may apply in Form No. 34F, and the Competent Authority in India may call for records, seek documents, and discuss the issue with the assessee or income-tax authorities. If a resolution is reached, it is communicated to the assessee, who must accept or reject it in writing within thirty days and, if accepting, furnish proof of withdrawal of pending appeals on the resolved issues.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Mutual agreement procedure under tax treaties governs cross-border dispute resolution, acceptance, and implementation of agreed outcomes.
Rule 44G provides the mutual agreement procedure for implementing agreements between India and a foreign country or specified territory where an assessee claims that tax authority action is not in accordance with the agreement. A resident assessee may apply in Form No. 34F, and the Competent Authority in India may call for records, seek documents, and discuss the issue with the assessee or income-tax authorities. If a resolution is reached, it is communicated to the assessee, who must accept or reject it in writing within thirty days and, if accepting, furnish proof of withdrawal of pending appeals on the resolved issues.
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