Cross-border tax disputes: ITAT orders to overrule MAP outcomes, says CBDT

Direct tax board issues detailed guidance on mutual agreement procedure, or MAP

Cross-border tax disputes over transfer pricing adjustments, permanent establishment between assesses and tax authorities of countries with which India has tax treaties and vice versa, can be resolved by an alternative resolution mechanism, called mutual agreement procedure, the direct tax board has said. 

Besides, if disputes arose because some items are classified as expenditure or income that would draw tax, those can also be sorted out using this mechanism, the Central Board of Direct Taxes (CBDT) said in its recent detailed guidance on MAP. The guidance was issued after the action plan following direction by action plan on the Base Erosion