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    <title>2026 (5) TMI 33 - ITAT BANGALORE</title>
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    <description>Transfer pricing disputes covered by a Mutual Agreement Procedure resolution under the India-Japan tax treaty are to be given effect only after the assessee withdraws the related appeal grounds. Under Rule 44G, the Assessing Officer passes effect orders once the appeal on the resolved issue is withdrawn. Here, the assessee stated that it would accept the MAP resolution reached between the competent authorities of India and Japan for transactions with its associated enterprises in Japan and sought withdrawal of the corresponding ground of appeal. The departmental representative raised no objection to withdrawal.</description>
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      <link>https://www.taxtmi.com/caselaws?id=790831</link>
      <description>Transfer pricing disputes covered by a Mutual Agreement Procedure resolution under the India-Japan tax treaty are to be given effect only after the assessee withdraws the related appeal grounds. Under Rule 44G, the Assessing Officer passes effect orders once the appeal on the resolved issue is withdrawn. Here, the assessee stated that it would accept the MAP resolution reached between the competent authorities of India and Japan for transactions with its associated enterprises in Japan and sought withdrawal of the corresponding ground of appeal. The departmental representative raised no objection to withdrawal.</description>
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