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Arm's length price determination continues despite agreement application, while bilateral negotiations must follow the relevant tax treaty. Mere filing of an application for an agreement under the rules does not suspend the operation of Chapter X of the Act for determination of arm's length price until the agreement is entered into. In bilateral or multilateral cases, negotiations between the competent authority of India and the competent authority of the other country or countries must be carried out in accordance with the applicable tax treaty.
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Provisions expressly mentioned in the judgment/order text.
Arm's length price determination continues despite agreement application, while bilateral negotiations must follow the relevant tax treaty.
Mere filing of an application for an agreement under the rules does not suspend the operation of Chapter X of the Act for determination of arm's length price until the agreement is entered into. In bilateral or multilateral cases, negotiations between the competent authority of India and the competent authority of the other country or countries must be carried out in accordance with the applicable tax treaty.
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