<h1>CBDT Resolves 100+ Transfer Pricing Disputes with USA, Reopens Bilateral APA Program Under 2015 Framework Agreement.</h1> The Central Board of Direct Taxes (CBDT) has resolved over 100 transfer pricing disputes with the USA under a Framework Agreement finalized in January 2015. This agreement, part of the Mutual Agreement Procedure (MAP) in the India-USA Double Taxation Avoidance Convention, addresses disputes in the Information Technology and IT-enabled Services sectors. The resolution has led to the reopening of the US bilateral Advance Pricing Agreement (APA) program to India. MAP programs with Japan and the UK are also progressing. The CBDT anticipates that these initiatives will enhance tax certainty and attract multinational companies to India.