“dispute resolution panel”

Assessment ProceduresSection 144CSection 144C2,746 judgments

TREND MICRO AUSTRALIA PROPRIETARY LIMITED,AUSTRALIA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE INT. TAX 3(1)(1), DELHI

In the result, assessment order is quashed and appeal of the assessee is allowed

ITA 2730/DEL/2023[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं. 2730/धिल्ली/2023 (नि.व. 2020-21) Trend Micro Australia Proprietary Ltd., Level-15, 1-Pacific Highway North, Sydney Nsw 2060, Australia 2060 ...... अपीलार्थी/Appellant Pan: Aaect-4864-E बिाम Vs. Deputy Commissioner Of Income Tax, International Taxation, Circle 3(1)(1), Civic Centre, .....प्रनिवादी/Respondent New Delhi 110002 अपीलार्थी द्वारा/ Appellant By: Shri Vishal Kalra, Advocate, Ms. Reema Grewal, Chartered Accountant & Ms. Snigdha Gautam, Advocate प्रनिवादीद्वारा/Respondent By: Shri M.S Nethrapal, Cit-Dr सुिवाई की निथर्थ/ Date Of Hearing : 22/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 20/03/2026 आदेश/Order Per Vikas Awasthy, Jm:

For Appellant: Shri Vishal Kalra, Advocate, Ms. Reema GrewalFor Respondent: Shri M.S Nethrapal, CIT-DR

Section 143(3)Section 144CSection 144C(13)

ground of limitation. 2 3. Shri Vishal Kalra, appearing on behalf of the assessee submits that pursuant to directions of the Dispute Resolution Panel (DRP) dated 30.05.2023, the Assessing Officer (AO) was duty bound to passed final assessment order within one month from the end of the month in which

HOME CREDIT INTERNATIONAL A.S.,CZECH REPUBLIC vs. ASSISTANTDEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION, GURGAON HARYANA

In the result, the appeal of the assessee is allowed

ITA 3846/DEL/2023[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22

Bench: Shri Vikas Awasthy, Hon’Ble & Smt. Renu Jauhri, Hon’Ble

Section 143(3)Section 144CSection 144C(8)Section 153Section 282

Income Tax Act, 1961 [hereinafter referred to as, “Act”] for A.Y. 2021-22 in consonance with the order dated 18.09.2023 passed by the Dispute Resolution Panel (DRP)- u/s 144C of the Act. 2. The assessee has raised following grounds of appeal: “1. That the Assessing Officer ('AO') erred on facts ... been passed beyond the time period specified under Section 153 of the Act. 3. Without prejudice, the directions, dated 18.09.2023 issued by the Dispute Resolution Panel ("DRP") are void-ab-initio and bad in law for the reason that the said directions do not mention the Document Identification Number

THE BANK OF TOKYO MITSUBISHI UFJ,NEW DELHI vs. DCIT, CIRCLE- 3(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 7212/DEL/2017[2013-14]Status: DisposedITAT Delhi13 Mar 2026AY 2013-14

Section 143(2)Section 143(3)Section 144Section 44C

Income Tax Act, 1961\n(hereinafter referred to as ‘the Act') dated 31-10-2017 pursuant to the directions\nof the Hon'ble Dispute Resolution Panel (DRP) vide order dated 18-09-2017 u/s\n144C(5) of the Act for Assessment Years (AY.) 2013-14.\n\n2. Brief facts ... assessee on\nexternal commercial borrowings. This objection of the assessee has not been subject\nmatter of the direction by the learned Dispute Resolution Panel. In short, the learned\ndispute resolution panel did not give any direction to the AO on this account. However,\nas no fresh facts are required

JUBILANT INGREVIA LIMITED,BHARTIAGRAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, MORADABAD

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 5851/DEL/2024[2021-22]Status: DisposedITAT Delhi11 Mar 2026AY 2021-22

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanjubilant Ingrevia Ltd, Vs. Acit-1, Bhartiagram Bhartia Gram, So Moradabad, Up Dhanaura, Jyotiba Phule Nagar, Uttar Pradesh (Appellant) (Respondent) Pan: Aaecj6722D

For Appellant: Shri K. M. Gupta, AdvFor Respondent: Shri Jitendra Singh, CIT DR

Section 115Section 143(1)Section 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 154Section 234ASection 234CSection 270A

r.w.s. 144C(13) of the Income Tax Act, 1961 (for short ‘the Act’) inconsonance with the order passed by the Dispute Resolution Panel (DRP)- 2, New Delhi dated 30.09.2024 u/s 144C(5) and order of TPO dated 30.10.2023 passed u/s 92CA(3) of the Act. 2. The assessee has raised ... circumstances of the case and in law, the impugned order/ directions passed/issued by Ld. Assessing Jubilant Ingrevia Ltd Officer (AO/ACIT) and Hon'ble Dispute Resolution Panel (DRP) respectively for the year under consideration is bad in law. 2. That on the facts and circumstances of the case

GE ENGINE SERVICES LLC,UNITED STATES OF AMERICA vs. ASSISTANT COMMISSIONER OF INCOME TAX, NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 3700/DEL/2023[AY 2021-22]Status: DisposedITAT Delhi11 Mar 2026

Section 143(2)Section 143(3)Section 144CSection 9(1)

Income Tax Act, 1961\n(hereinafter referred to as 'the Act') dated 20.10.2023 pursuant to the directions of\nthe Hon'ble Dispute Resolution Panel (DRP) vide order dated 13.09.2023 u/s\n144C(5) of the Act for Assessment Years (AY.) 2021-22.\n2.\nGround no. 1 of the appeal ... impugned receipts was raised before the Hon'ble Tribunal, was\ndisposed of and the matter was remanded to the Hon'ble Dispute Resolution Panel with the\nfollowing directions\n\"9. This is a classic case wherein the directions of the lid. DRP have been circumvented by\nthe Assessing Officer

MITESH SURESH SHAH,MUMBAI vs. ITO INTERNATIONAL TAXATION WARD 4(2)(1), MUMBAI

In the result, the appeal filed by the assessee stands partly allowed with no order as to cost

ITA 5593/MUM/2025[2016-17]Status: DisposedITAT Mumbai10 Mar 2026AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarmitesh Suresh Shah Vs. Ito-International Tax 401, 4Th Floor, Blue Heaven, Ward-4(2)(1), Mumbai Nehru Road, Vakola, Kautilya Bhavan, Pipeline, Santacruz (East), Bandra Kurla Complex, Mumbai-400055 Bandra (East), Mumbai- 400051 Pan/Gir No. Auxps9395K (Applicant) (Respondent) Assessee By Ms. Dinkle Hariya, Adv. Revenue By Shri Krishna Kumar (Sr. Dr.) Date Of Hearing 11.02.2026 Date Of Pronouncement 10.03.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 29.03.2022 Passed U/S 144C Of The Income Tax Act, 1961 (‘The Act’), By The Office Of The Income Tax Officer Ward 4(2)(1), Mumbai For The Assessment Year 2016-17. The Following Grounds Are Reproduced Below: “1. The Order Is Bad In Law, Illegal & Without Jurisdiction

Section 144CSection 147Section 68

Ward - 4(2)(1), Mumbai ['A.O.'] u/s. 147 r.w.s. 144C(13) of the Act dated 03.01.2023, pursuant to the directions of the Dispute Resolution Panel ['Ld. DRP'], is bad in law, illegal and without jurisdiction, as the same is framed in breach of the statutory provisions and the scheme ... passed by the Assessing Officer u/s 147 r.w.s. 144C(13) of the Act was passed pursuant to the direction issued by the Dispute Resolution Panel u/s 144C(5) of the Act was challenged before the Hon’ble Bombay High Court. 4. The Hon’ble Bombay High Court, vide its order

ZARAH RAFIQUE MALIK,MUMBAI vs. ITO (INT TAX) WARD-3(2)(1), MUMBAI

ITA 5159/MUM/2025[2022-23]Status: DisposedITAT Mumbai10 Mar 2026AY 2022-23

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri Vikram Singh Yadav, Hon’Blezarah Rafique Malik Income Tax Officer, (Int.Tax) B/1703, Vivarea Condominium, Ward- 3(2)(1), Mumbai Vs. Sane Guruji Marg, Jacob Circle, Mahalaxmi East Mumbai – 400 011 Pan : Adcpm8960G (Appellant) (Respondent)

For Appellant: Shri K Gopal, Adv. & Shri Oom KandalkarFor Respondent: Shri Krishna Kumar, Sr. DR

Section 120(4)(b)Section 127Section 143(2)Section 143(3)Section 144BSection 153(1)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “I”, MUMBAI Before Justice (Retd.) C V Bhadang, Hon’ble President & Shri

FIRSTRAND BANK LIMITED - INDIA BRANCH,MUMBAI vs. ASSISTANT COMMISSIONER , MUMBAI

In the result, appeal of the assessee is allowed

ITA 4580/MUM/2024[2020-21]Status: DisposedITAT Mumbai10 Mar 2026AY 2020-21

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri Paras Savla, AdvocateFor Respondent: Shri Bhagirath Ramawat, Sr. DR

Section 133(6)Section 144C(5)Section 92C

GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the final assessment order passed pursuant to the directions of the Dispute Resolution Panel-1, Mumbai, (DRP) vide order No. ITBA/DRP/F/144C(5)/2024- 25/1065484084(1) dated 07.06.2024, u/s. 144C(5) of the Income-tax Act, 1961 (hereinafter referred ... FirstRand Bank Ltd. AY 2020-21 1.1. The learned Transfer Pricing Officer ("TPO")/ Assessing Officer ("AO") under the directions of Hon'ble Dispute Resolution Panel ("DRP") has erred in making upward adjustment of Rs. 4,46,66,174/- without appreciating the detailed analysis carried out by the assessee in terms

GEMOLOGICAL INSTITUTE OF AMERICA, INC.,UNITED STATES OF AMERICA vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), RANGE 2(3)(2) - MUMBAI, MUMBAI

Accordingly this ground raised by the assessee stands allowed in terms of above directions

ITA 8248/MUM/2025[2020-21]Status: DisposedITAT Mumbai09 Mar 2026AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankargemological Institute Of Vs. Acit (International America Taxation), Range - 5345, The Robert Mouawad 2(3)(2) Mumbai Campus, Armada Drive, Room No. 610, 6Th Carlsbad, Floor, Kautilya Bhavan, California - 092008 Bandra Kurla Complex, Bandra (East) Mumbai – 400051 Pan/Gir No. Aadcg7962K (Applicant) (Respondent) Assessee By Shri J.D. Mistry-Sr. Adv./Gunjan Kakkad Revenue By Shri Krishna Kumar (Sr. Dr.) Date Of Hearing 03.02.2026 Date Of Pronouncement 09.03.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 03.09.2025 Passed U/S 143(3) R.W.S. 254 Of The Income Tax Act, 1961 (‘The Act’), By The Office Of The Assistant Commissioner Of Income Tax, Circle 2(3)(2), Mumbai, For The Assessment Year 2020-21. The Following Grounds Are Reproduced Below:

Section 143(3)Section 144C(5)Section 244ASection 92C

America, Inc. “1:0 Re.: Non-consideration of the correct amount of royalty for the year: 1 1 The Assessing Officer / the Dispute Resolution Panel have erred in holding that the Appellant's income by way of royalty for the year ... assessee filed a modified return of income on 30.06.2025 under section 92CD of the Act, after the date of hearing before the Dispute Resolution Panel (DRP), incorporating the revised computation of royalty in accordance with the APA. 5 Gemological Institute of America, Inc. 6. However, the DRP passed its directions

ELARA INDIA OPPORTUNITIES FUND LIMITED,MAURITIUS vs. DEPUTY COMMISSIONER OF THE INCOME TAX (INTERNATIONAL TAXATION) - 2(2)(1), MUMBAI

ITA 5859/MUM/2025[2019-2020]Status: DisposedITAT Mumbai09 Mar 2026AY 2019-2020

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n\"I\" BENCH MUMBAI\nBEFORE HON'BLE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER

SRIDHARAN SHANMUGAM,SALEM vs. ITO, INTERNATIONAL TAXATION WARD,, COIMBATORE

In the result the appeal of the assessee is allowed

ITA 544/CHNY/2025[2022-23]Status: DisposedITAT Chennai03 Mar 2026AY 2022-23

Bench: Shri S.S.Viswanethra Ravi & Shri S.R.Raghunatha

For Appellant: Shri. P.M.Kathir, AdvocateFor Respondent: Ms. C.Vatchala, CIT

Section 143(3)Section 144(7)Section 144C(1)Section 144C(5)Section 69Section 69A

Income Tax Act, 1961 (hereinafter the ‘Act’) for the assessment year 2022-23 in pursuant to the directions of the Dispute Resolution Panel-2, Bengaluru vide order dated 27.12.2024. :-2-: ITA. No:544/Chny/2025 2. The only issue raised by the assessee is that the AO has erred in making ... bangalore.secretary.drp2@incometax.gov.in. Kindly refer to the above. The additional evidence relied upon by the assessee Sri. Sridharan Shanmugam(PAN: BNOPS3984B) before the Hon'ble Dispute Resolution panel (DRP) are discussed hereunder:- 1. Explanation on cash deposits of Rs. 75,00,000/-. The assessee has submitted that he had desired to acquire

ASSITANT COMMISSIONER OF INCOME TAX , DEHRADUN vs. POWER MACHINES, NEW DELHI

In the result, appeal preferred by the revenue is dismissed

ITA 133/DDN/2024[2013-14]Status: DisposedITAT Dehradun27 Feb 2026AY 2013-14

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Ansaul Sachar, AdvFor Respondent: Sh. Mohan Lal Joshi, Sr. DR

Section 143(3)Section 144Section 271(1)(c)Section 69

completed under section 144/144C(13) of the Income Tax Act, 1961 (in short ‘Act’) in 2 consonance with directions of the Ld Dispute Resolution Panel (DRP) at Rs. 106,810,379/-. Thereafter, the assessee preferred an appeal to Income Tax Appellate Tribunal (ITAT) wherein the tribunal directed the Assessing Officer

COMER INDUSTRIES INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, CIRCLE 2(2)(1), BANGALORE, BANGALORE

In the result, the appeal by the assessee is dismissed

ITA 1228/BANG/2025[2017-18]Status: DisposedITAT Bangalore27 Feb 2026AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Balasubramanyam, CAFor Respondent: Shri Shivanand Kalakeri, CIT(DR)(ITAT), Bengaluru

Section 139(1)Section 234CSection 263Section 36(1)(va)

raised by the ld AR is that the impugned Assessment order is passed by the ld AO pursuant to directions of the Ld Dispute resolution panel and therefore same could not be revised by the ld PCIT. he has relied up on several Judicial Precedents such as Barclays Bank

OWENS CORNING (SINGAPORE) PTE LTD,MUMBAI vs. THE DCIT (INT TAX) CIRCLE-3(2)(2), MUMBAI

In the result, the appeal filed by the assessee is allowed

ITA 5161/MUM/2025[2023-24]Status: DisposedITAT Mumbai26 Feb 2026AY 2023-24

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2023-24 Owens Corning (Singapore) Deputy Commissioner Of Pte Ltd., Income Tax (International Tax), C/O. Owens Corning (India) Vs. Circle-3(2)(2), Pvt. Limited, 6Th Floor, 7Th Floor, Alpha Building, Kautilya Bhavan, Hiranandani Gardens, Bandra Kurla Complex, Powai, Mumbai-400051. Maharashtra-400076. Pan : Aabco5666L (Appellant) (Respondent) For Assessee : Shri Sandeep Bhalla For Revenue : Shri Krishna Kumar, Sr.Dr Date Of Hearing : 02-12-2025 Date Of Pronouncement : 26-02-2026 O R D E R Per Vikram Singh Yadav, A.M : The Assessee Has Filed The Present Appeal Against The Final Assessment Order Dated 10-07-2025, Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 („The Act‟), Pursuant To The Directions Issued By The Learned Dispute Resolution Panel-2, Mumbai, ("Ld.Drp"), Pertaining To Assessment Year (Ay) 2023-24, Wherein The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri Sandeep BhallaFor Respondent: Shri Krishna Kumar, Sr.DR

Section 115ASection 142(1)Section 143(2)Section 143(3)Section 234Section 234BSection 9(1)(vii)Section 90(2)

passed u/s. 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 („the Act‟), pursuant to the directions issued by the Learned Dispute Resolution Panel-2, Mumbai, ("Ld.DRP"), pertaining to Assessment Year (AY) 2023-24, wherein the assessee has raised the following grounds of appeal: 2 “1.0 Re: Treating ... fabrication charges received as 'fees for technical services': 1.1 The Assessing Officer ('AO')/ Dispute Resolution Panel ('DRP') has erred in taxing the fabrication charges received by the Appellant of INR 21,96,83,550 during the year under consideration by treating the same as 'fees for technical services' in terms

PARAMETRIC TECHNOLOGY (INDIA) PRIVATE LIMITED,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(2), BENGALURU

In the result, the appeal of the assessee is partly allowed

ITA 2514/BANG/2024[2021-22]Status: DisposedITAT Bangalore24 Feb 2026AY 2021-22

For Appellant: Shri Darpan Kirpalani, CAFor Respondent: Dr. Divya K.J, CIT (DR)

Section 143(3)

learned transfer pricing officer held that\nits entire revenue is from software sales in this company is functionally like the\ntaxpayer.\nThe learned dispute resolution panel also held that the revenue from sale of\nsoftware is Rs. 40.73 crores against total revenue of Rs. 42.58 crores which is\nmore than

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DCIT, CIRCLE 3(1)(1), BANGALORE

ITA 2525/BANG/2024[AY 2021-22]Status: DisposedITAT Bangalore23 Feb 2026

Bench: MS. PADMAVATHY S., ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhur AgarwalFor Respondent: Dr. Divya K. J

Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 234ASection 270ASection 92C

read with Section 144C(13) of the Income Tax Act, 1961[hereinafter referred to as ‘the Act’], as per the directions issued by [Dispute Resolution Panel (1)], Bengaluru [for short ‘DRP’], on 25/09/2024 under Section 144C(5) of the Act. 2. The Assessee has raised following grounds of appeal

M/S. NTT DATA GLOBAL SERVICES PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 5, BANGALORE

ITA 2533/BANG/2019[2015-16]Status: DisposedITAT Bangalore23 Feb 2026AY 2015-16

Section 133(6)Section 143(3)Section 144C(13)Section 144C(5)

read with Section 144C(13)\nof the Income Tax Act, 1961[hereinafter referred to as `the Act'], as\nper the directions issued by Dispute Resolution Panel (2), Bengaluru\n[for short 'DRP'], on 09/09/2019 under Section 144C(5) of the Act.\n2.\nThe Assessee has raised following grounds of appeal ... section 143(3) read\nwith section 144C(13) of the Income-tax Act 1961 ('the Act') in\npursuance of the directions issued by Dispute Resolution Panel\n(hereinafter referred to as the \"Hon'ble DRP\"), Bengaluru dated 09\nSeptember 2019 under section 144C(5) of the Act inter-alia

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 6(3)(1), MUMBAI

ITA 1495/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11

Section 133(6)Section 92D

circumstances of the case, the learned\nTransfer Pricing Officer ('TPO') and the learned Assessing Officer ('AO')\nunder the directions of the Hon'ble Dispute Resolution Panel ('DRP') erred\non facts and in law in making an addition ... circumstances of the case, the learned\nTransfer Pricing Officer ('TPO') and the learned Assessing Officer ('AO')\nunder the directions of the Hon'ble Dispute Resolution Panel ('DRP') erred\non facts and in law in making an addition

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 3(1), MUMBAI

In the result, appeals filed by the assessee stands partly allowed

ITA 2047/MUM/2014[2009-10]Status: DisposedITAT Mumbai20 Feb 2026AY 2009-10

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 133(6)Section 92D

circumstances of the case, the learned Transfer Pricing Officer ('TPO') and the learned Assessing Officer ('AO') under the directions of the Hon'ble Dispute Resolution Panel ('DRP') erred on facts and in law in making an addition ... circumstances of the case, the learned Transfer Pricing Officer ('TPO') and the learned Assessing Officer ('AO') under the directions of the Hon'ble Dispute Resolution Panel ('DRP') erred on facts and in law in making an addition

ASSISTANT COMMISSIONER OF INCOME TAX, DEHRADUN vs. SEABIRD EXPLORATION FZ-LLC, NEW DELHI

In the result, appeal of the Revenue is dismissed

ITA 134/DDN/2024[2012-13]Status: DisposedITAT Dehradun18 Feb 2026AY 2012-13

Bench: SHRI YOGESH KUMAR U.S (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 250Section 271(1)(c)Section 44B

order and the total income was proposed at INR 28,83,36,180/-. Thereafter the assessee filed objections before the ld. Dispute Resolution Panel (“DRP”) who vide order dated 03.04.2019 has confirmed the addition on account of income @ 10 % computed u/s 44BB of the Act and delete the adjustment proposed

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