MAP resolution for transfer pricing takes effect after withdrawal of the resolved appeal ground under treaty rules.

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Full Text of the Document

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....Transfer pricing disputes resolved under the India-Japan MAP can be given effect only after the assessee withdraws the appeal ground covered by the resolution. Article 25 of the treaty was invoked for the transaction with Japanese associated enterprises, and the assessee stated that it would accept the competent authorities' resolution. Under Rule 44G, the Assessing Officer is to pass orders giving effect to the MAP resolution once the related appeal is withdrawn. The assessee accordingly requested withdrawal of the relevant ground, and the tax department raised no objection.....