https://www.taxtmi.com/article/detailed?id=16540 Mutual Agreement Procedure under the Income-tax Act, 2025 remains the treaty mechanism for resolving taxation not in accordance with a double taxation avoidance agreement, but Section 533 largely reproduces the earlier framework without curing India's prolonged MAP backlog. Rule 121 and Form 55 improve the application stage through more structured disclosures, yet they do not address the negotiation bottleneck, under-resourced administration, lack of mandatory arbitration, parallel domestic appeal proceedings, or limited transparency. The article proposes targeted reforms including a 24-month resolution timeline, MAP-appeal coordination, specialist resourcing, and public statistics. en-us Sat, 30 May 2026 08:32:59 +0530 Sat, 30 May 2026 08:32:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=16540 Mutual Agreement Procedure under the Income-tax Act, 2025 remains the treaty mechanism for resolving taxation not in accordance with a double taxation avoidance agreement, but Section 533 largely reproduces the earlier framework without curing India's prolonged MAP backlog. Rule 121 and Form 55 improve the application stage through more structured disclosures, yet they do not address the negotiation bottleneck, under-resourced administration, lack of mandatory arbitration, parallel domestic appeal proceedings, or limited transparency. The article proposes targeted reforms including a 24-month resolution timeline, MAP-appeal coordination, specialist resourcing, and public statistics. Articles Income Tax Sat, 30 May 2026 08:32:59 +0530 https://www.taxtmi.com/article/detailed?id=16540