Revision of agreement under income-tax rules allows changes for altered assumptions, law changes, or cross-border authority requests. Revision of an agreement may be undertaken by the Board where there is a change in critical assumptions, failure to meet a condition, a change in law affecting covered matters, or a request from the competent authority of the other country. The Board may act suo motu or on request of the assessee, the competent authority of India, or the Principal Chief Commissioner of Income-tax (International Taxation). Except where the assessee itself seeks revision, the assessee must be heard and agree to the proposed revision; otherwise, the agreement may be cancelled. The revised agreement must state the period of application of the original agreement and the effective date of the revision.
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.
Revision of agreement under income-tax rules allows changes for altered assumptions, law changes, or cross-border authority requests.
Revision of an agreement may be undertaken by the Board where there is a change in critical assumptions, failure to meet a condition, a change in law affecting covered matters, or a request from the competent authority of the other country. The Board may act suo motu or on request of the assessee, the competent authority of India, or the Principal Chief Commissioner of Income-tax (International Taxation). Except where the assessee itself seeks revision, the assessee must be heard and agree to the proposed revision; otherwise, the agreement may be cancelled. The revised agreement must state the period of application of the original agreement and the effective date of the revision.
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