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of <h1>India-USA MoU Extends Tax Collection Suspension to Indian Residents in Transfer Pricing Cases u/s 119.</h1> The Indo-US Double Taxation Avoidance Convention (DTAC) includes a Mutual Agreement Procedure (MAP) to prevent double taxation. An MoU between India and the USA provides for the suspension of tax collection during the MAP process, requiring a bank guarantee equal to the disputed tax amount. Initially applicable to US residents, this MoU now extends to Indian residents involved in transfer pricing cases where MAP is invoked by a US resident. Tax collection is suspended upon confirmation of MAP pendency and receipt of a bank guarantee. These instructions are issued under Section 119 of the Income Tax Act.
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