Saturday 26 October 2013

US DTAA/MAP : Bombay HC rejects Revenue's interpretation of 'admitted' in CBDT's Instruction No. 2/2

IT/ILT : MAP invocation application under DTAA before US Competent Authority and furnishing Bank Guarantee to Revenue in India suspends assessment & collection of taxes in India. The word "admitted" by Indian Competent Authority in CBDT's Instruction No. 2 of 2003 only means that the Competent Authority in India has to admit i.e. acknowledge that the MAP proceedings have been invoked by tax payers through the Competent Authority in USA. It does not mean that the invocation of the MAP proceedings


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