India's Central Board of Direct Taxes (CBDT) has issued a release providing clarification of India’s position on the acceptance of MAP and bilateral APAs in cases where paragraph 2 of Article 9 of the OECD Model (or equivalent) is absent from a relevant tax treaty. Paragraph 2 relates to corresponding adjustments. The release notes that the CBDT has examined the matter and decided that transfer pricing MAP and bilateral APA applications will be accepted regardless of the presence or otherwis…