Mutual agreement procedure

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...., present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.] 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive a....

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.... preceding paragraphs. When it seems advisable in order to reach agreement to have an oral exchange or opinions, such exchange may take place through a Commission consisting of representatives of the competent authorities of the Contracting States.     *************** NOTES:- 1.  Substituted vide Notification No. 39/2026 dated 30-03-2026 before it was read as,....