Indo-US Double Taxation Avoidance Convention (DTAC)- Suspension of Collection during Mutual Agreement Procedure - Section 90 of the Income Tax 1961 - Double Taxation Relief - Where agreement exist

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..... lection during Mutual Agreement Procedure - Section 90 of the Income Tax 1961 - Double Taxation Relief - Where agreement exist. INSTRUCTION NO. 10/2007 DATED 23-10-2007 . Article 27 of the Indo-USA DTAC provides for Mutual Agreement Procedure (MAP) for avoidance of double taxation. Paragraph 4 of Article 27 authorises the competent authorities to develop appropriate bilateral procedures, .....

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..... to the amount of tax under dispute and interest accruing thereon as per the provisions of the Income-tax Act. 3. Now references have been received for extending the applicability of MoU to Indian resident entities in cases where Mutual Agreement Procedure has been invoked by the US resident. In order to avoid hardship to Indian resident taxpayers especially in cases involving transfer pricing, w .....

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..... mation regarding pendency of MAP from the Foreign Tax and Tax Research Division of the Central Board of Direct Taxes and ( ii ) on receipt of a bank guarantee in the model draft format annexed to the MoU for an amount calculated in accordance with the manner indicated therein. 5. All the other conditions of MoU as enumerated in Instruction No. 2 of 2003 dated 28-4-2003 shall remain the same. .....

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