Mutual agreement procedure governs cross-border tax disputes, requiring acceptance, appeal withdrawal, and assessment adjustments after resolution. Mutual agreement procedure under an agreement with a foreign country or specified territory may be invoked by a resident assessee by application to the competent authority of India in Form No. 55. The competent authority may call for records, hold discussions, and endeavour to reach a mutually agreeable resolution within an average period of twenty-four months. Where a resolution is arrived at, it is to be communicated to the assessee, accepted or declined within one month, and, upon acceptance with proof of withdrawal of any pending appeal, given effect to by the Assessing Officer by written order, with consequential adjustment of tax, interest or penalty already determined.