Mutual Agreement Procedure enables residents to seek cross-border tax dispute resolution and implement agreed adjustments upon acceptance. The rules establish a procedure for residents to invoke the Mutual Agreement Procedure via application to the Competent Authority of India; the Competent Authority must examine records on references from foreign counterparts, seek resolution under relevant agreements, communicate outcomes to senior tax officials where necessary, and require Assessing Officers to give effect to agreed resolutions once the assessee accepts the resolution and withdraws related appeals, with corresponding adjustments to tax, interest or penalty as permitted under the Income-tax Act and rules.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Mutual Agreement Procedure enables residents to seek cross-border tax dispute resolution and implement agreed adjustments upon acceptance.
The rules establish a procedure for residents to invoke the Mutual Agreement Procedure via application to the Competent Authority of India; the Competent Authority must examine records on references from foreign counterparts, seek resolution under relevant agreements, communicate outcomes to senior tax officials where necessary, and require Assessing Officers to give effect to agreed resolutions once the assessee accepts the resolution and withdraws related appeals, with corresponding adjustments to tax, interest or penalty as permitted under the Income-tax Act and rules.
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