MAP A Memorandum of Understanding (MoU) has been in place between India and the United States since 2002, for the purposes of the Mutual Agreement Procedure (MAP) under the tax treaty. This MoU obliges the competent authorities of the two countries to defer assessment or suspend collection of taxes, including any related interest or penalties, during negotiations initiated by a US resident taxpayer under the MAP proceedings. However, the taxpayer has to furnish a bank guarantee of an amount equal to the amount of tax under dispute and interest accruing thereon as per the provisions of the Indian Income Tax...