Agreement cancellation safeguards require hearing, written reasons, and inter-authority communication before cancellation or void ab initio declaration.

Cancellation of an agreement may be ordered by the Board where compliance audit shows failure to comply with the agreement, the annual compliance report is not filed in time, the report contains material errors, or cancellation is otherwise required under the linked provisions. Before cancellation, the assessee must be given a reasonable opportunity of being heard, and in bilateral or multilateral cases the competent authority of India must communicate the proposed cancellation and reasons to the other competent authority or authorities.

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