October 2003 and 18 December 2003 constituted an
understanding employing the mutual agreement procedure as provided for in Article 25 of
the Indo-Swiss treaty
Indo-Swiss treaty, we are of the view that the mutual
agreement arrived at by the competent authorities of two countries, is good enough ... authorized representative. Article 25 of the said treaty prescribes the mutual
agreement procedure whereby if a resident of a contracting State considers that the
action
Indo- Swiss treaty, we are of the view
that the mutual agreement arrived at by the competent authorities of
two countries, is good enough ... authorized representative. Article
25 of the said treaty prescribes the mutual agreement procedure
whereby if a resident of a contracting State considers that the action
Indo-
Swiss treaty, we are of the view that the mutual agreement arrived at by
the competent authorities of two countries, is good enough ... authorized representative. Article 25 of the said treaty
prescribes the mutual agreement procedure whereby if a resident of
a contracting State considers that the action
Swiss Federal Tax
Administration does not constitute a mutual agreement as
contemplated by Article 25(3) of the Tax Treaty.
1b. On the facts ... Indo-
Swiss treaty, we are of the view that the mutual agreement
arrived at by the competent authorities of two countries, is good
enough
Pertinently, it is observed that there has been a Mutual Agreement
Procedure (MAP) resolution for A.Y. 2007-08 in the group cases ... Court. The
ld. AR for the assessee submitted that in the mutual agreement proceeding,
one of the receipt was borrowed service charges and since then
Assessing Officer did not recognise the binding nature of the Mutual
Agreement Procedure (MAP) order relevant to the issue under consideration.
Further, Ld Counsel ... been accepted and decided in favour of
the assessee under Mutual Agreement Procedure (MAP) resolution and therefore the same is not
taxable. The ld. Counsel
Department withdrew the appeals as
the issue was resolved under Mutual Agreement Procedure (MAP). Considering the
facts of the case in totality and following ... Assessing Officer did not recognise the binding nature of the Mutual Agreement
Procedure (MAP) order relevant to the issue under consideration. Further, Ld
Counsel
justified in giving relief to the assessee based on Mutual
Agreement Procedure of US- incorporated associated enterprises of the
Assessee, despite the fact that Assessee ... party to any of the Mutual
Agreement Procedure?
4. Whether on facts and in the circumstances of the case
justified in giving relief to the assessee based on Mutual
Agreement Procedure of US- incorporated associated enterprises of the
Assessee, despite the fact that Assessee ... party to any of the Mutual
Agreement Procedure?
4. Whether on facts and in the circumstances of the case
