In the context of tax treaties, what is the need for Mutual Agreement Procedure (MAP)? Outline the steps involved in MAP application process.

Answer 6(b) Need for MAP Double Taxation Avoidance Agreements ('tax treaties') are available for capturing and curtailing juridical double taxation. Tax treaties generally do not cover instances of economic double taxation. MAP provides relief in cases of economic double taxation. MAP also provides relief in cases where automatic relief, such as tax credits, tax exemption, etc. are not available. Steps involved in the MAP application process Brief facts and background of the case must be summarized. Contentions of Indian Revenue must be summarized in the application. The net tax and interest impact only by virtue of transfer pricing adjustment is computed. The note of transactions only relating to one country (in one application), e.g., USA, UK, etc. All documents including tax returns, TP study, notices, submissions, orders, etc. must be furnished. Relevant judicial precedence and their applicability to taxpayer's case must be demonstrated.