Attorney General also relied heavily upon an
admission made under the mutual agreement procedure (MAP)
under Article 27 of the DTAA, in which ... Article 27
is also important and reads as under:
“ARTICLE 27 - Mutual agreement procedure –
22
1. Where a person considers that the actions
been accepted by the assessee; (iii) is determined by an advance pricing agreement entered into by the assessee under section 92CC; (iv) is made ... result of resolution of an assessment by way of the mutual agreement procedure under an agreement entered into under section 90 or section
unions of the employees was held on
21.01.2014, in which a Mutual Agreement was entered upon. A copy of the
said mutual agreement is Annexed ... Annexure 'A-I'.
5. That after the Mutual Agreement dated 21.01.2014, the Council
of Ministers, in its meeting held on 24.6.2014, has taken
defendant No.2 even now
agree that they arrived at a mutual agreement in respect of the said payment.
The difference is between the version ... that mutual agreement.
While the defendant No.1 claims that mutual agreement to be of dividing the
property (after ousting the plaintiff therefrom) equally
some
other place.
5. According to applicant, on 23.12.2004, a mutual
agreement was executed between the non-applicant
Madhukar Gupta and the applicant Sharad Gupta ... specifying the same would be executed within four
days of the mutual agreement i.e. 23.12.2004. Therefore, it
was decided in the agreement dated
unions of the employees was held on
21.01.2014, in which a Mutual Agreement was entered
upon. A copy of the said mutual agreement ... Annexed as Annexure 'A-I'.
5. That after the Mutual Agreement dated
21.01.2014, the Council of Ministers, in its
meeting held
respondent after the quantum was arrived at by
mutual agreement, it would be paid after the completion of the
discharge.
6. Mr. Aditya Krishnamurthy, appearing ... same being mutually agreed upon. He
would submit that since the parties could not arrive at a consensus the
mutual agreement had failed. The parties
marketing area. This has been clearly brought out in the Mutual Agreement dated 12.03.1993 which has been duly presented on 12.03.1993 itself for registration whereas ... motive can be attributed against the appellant in respect of the Mutual Agreement. I have read the entire contents of Mutual Agreement. I find that
marketing area. This has been clearly brought out in the Mutual Agreement dated 12.03.1993 which has been duly presented on 12.03.1993 itself for registration whereas ... motive can be attributed against the appellant in respect of the Mutual Agreement. I have read the entire contents of Mutual Agreement. I find that
marketing area. This has been clearly brought out in the Mutual Agreement dated 12.03.1993 which has been duly presented on 12.03.1993 itself for registration whereas ... motive can be attributed against the appellant in respect of the Mutual Agreement. I have read the entire contents of Mutual Agreement. I find that
