https://www.taxtmi.com/caselaws?id=422843 A concluded Mutual Agreement Procedure settlement could not be deferred on the basis that the assessee had not disclosed Indian transfer pricing adjustments for a later assessment year. The amended Rule 44G required the competent authority to obtain relevant records and additional documents, but that procedural point did not justify withholding implementation of an already communicated and accepted settlement. The treaty-based MAP resolution, being beneficial to the assessee, had to be given effect despite domestic procedural objections. The assessment orders were therefore liable to be amended, with consequential refund and permissible interest, and the settlement was to be implemented in full for the relevant assessment years. en-us Fri, 22 Apr 2022 00:00:00 +0530 Mon, 22 Aug 2022 10:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=422843 A concluded Mutual Agreement Procedure settlement could not be deferred on the basis that the assessee had not disclosed Indian transfer pricing adjustments for a later assessment year. The amended Rule 44G required the competent authority to obtain relevant records and additional documents, but that procedural point did not justify withholding implementation of an already communicated and accepted settlement. The treaty-based MAP resolution, being beneficial to the assessee, had to be given effect despite domestic procedural objections. The assessment orders were therefore liable to be amended, with consequential refund and permissible interest, and the settlement was to be implemented in full for the relevant assessment years. Case-Laws Income Tax Fri, 22 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=422843