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8 December 2025
CBDT Issues Procedural Clarity to Implement MAP Resolution
 
The Central Board of Direct Taxes (CBDT) issued an office memorandum on 27 October 2025 to simplify the process followed after the finalization of a Mutual Agreement Procedure (MAP).

Once a MAP resolution is finalized, taxpayers must withdraw appeals or the relevant grounds of appeals, pending before the Commissioner of Income-tax (Appeals) [CIT(A)], confirm their acceptance of the MAP outcome, and submit proof of withdrawal for the relevant years.

While the procedure for taxpayers was clear, there was no corresponding process for the CIT(A) to formally acknowledge such withdrawal requests. This gap often delayed the implementation of MAP outcomes.

The new Office Memorandum addresses this by asking the office of the CIT(A) to issue an intimation accepting the withdrawal of the appeal. This intimation will now serve as valid proof of withdrawal for giving effect to the MAP resolution.

Our Comments

Given the already lengthy nature of MAP proceedings, this is a welcome move. It eases the procedural burden on taxpayers and provides clarity on the withdrawal process. However, it would have been helpful if CBDT had also prescribed a time limit within which such intimation must be issued, so that any further delays in implementing MAP resolutions can be avoided.

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