Circular No. 21/2015 — Dispute Resolution — MAP provisions
Date: 2015-12-10 Status: ACTIVE Category: Appeals & Dispute Resolution Binding on Department: Yes (Section 119 / Section 400 IT Act 2025)
Summary
Guidelines for Mutual Agreement Procedure (MAP) under tax treaties. MAP application may be filed concurrently with domestic appeal.
Key Directions
- MAP application may be filed concurrently with domestic appeal.
- Competent authority to endeavour to resolve within 2 years.
- MAP resolution binding on AO once mutual agreement is reached.
Applicability Under IT Act 2025
Saving Clause: Section 536 of IT Act 2025 saves circulars issued under the 1961 Act “so far as not inconsistent” with the new Act.
| Old Section (1961 Act) | New Section (2025 Act) | Consistent? |
|---|---|---|
| 144C | 272 | Yes |
Cross-References
Act Sections
Related Circulars
- None identified
Key Case Law (Circular Supremacy)
- To be populated — cases where this circular was cited/applied
Full Text
Full text to be added — see raw/circulars/ for PDF when available
Source
- Official: incometaxindia.gov.in/circulars