Mutual agreement procedure

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....ent his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25A, to that of the Contracting State of which he is a national. 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 Agreement. 2. The competent authori....

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....racting States may communicate with each other directly, for the purpose of reaching an agreement in the sense of the preceding paragraphs.]     *************** NOTES:-  1.  Substituted vide Notification No. 69/2025 dated 25-06-2025 before it was read as,  "1. Where a person of a Contracting State considers that the actions of one ....

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....t. Any agreement reached shall be implemented notwithstanding any time-limits in the domestic laws of the Contracting State. 3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement, any difficulties or doubts arising as to the interpretation of application of this Agreement. They may also consult together for the elimination of double taxation....