Rule 44G - Application for giving effect to the terms of any agreement under clause (h) of sub-section (2) of section 295

Mutual Agreement Procedure resolves cross-border tax disputes and sets the steps for implementing agreed treaty outcomes.

Mutual Agreement Procedure allows a resident assessee to apply in Form No.34F to the Competent Authority in India when a foreign tax authority's action is alleged to breach a treaty. The Competent Authority may accept references from foreign counterparts, gather records, and negotiate a resolution. If a resolution is reached, it is communicated to the assessee, who must accept in writing with proof of appeal withdrawal; thereafter the Competent Authority forwards the acceptance to senior tax officials and the Assessing Officer implements the resolution by written order and tax adjustment.