THE Central Board of Direct Taxes (CBDT) has decided to accept Transfer Pricing Mutual Agreement Procedure (MAP) and bilateral Advance Pricing Agreements (APAs) applications, regardless of the presence or otherwise of Article 9(2) (or its relevant equivalent Article) in the Double Taxation Avoidance Agreement (DTAA).

A number of references were received from time to time, regarding the acceptance of applications for Transfer Pricing MAP cases and Bilateral APAs, where the Associated Enterprise (AE) of the Indian entity was resident of a country with which India has entered into a DTAA. However the Agreement did not contain the provisions of Paragraph 2 of Article 9 (or its relevant equivalent Article) relating to 'Corresponding Adjustment'.