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“dispute resolution panel”

Assessment ProceduresSection 144CSection 144C2,746 judgments

The decision most relied on for dispute resolution panel is Commissioner of Income Tax v. Roca Bathroom Products (P) ltd. (445 ITR 537), cited in 269 judgments on BharatTax.

Leading authorities on dispute resolution panel

Commissioner of Income Tax v. Roca Bathroom Products (P) ltd.
445 ITR 537 · 2022 · High Court
269
citing judgments

The time limit for the Assessing Officer to pass a final assessment order under Section 144C(13) following directions from the Dispute Resolution Panel is determined by the specific provisions of Section 153, particularly Section 153(2A).

Shelf Drilling 4. In ACIT (International Taxation) v. Shelf Drilling Ron Tappmeyer Ltd.
177 Taxmann.com 262 · 2025 · Supreme Court
216
citing judgments

The Supreme Court has not reached a majority verdict on whether the time spent in Dispute Resolution Panel (DRP) proceedings under Section 144C should be included within the overall limitation period prescribed by Section 153(3). Consequently, the legal position on the interplay between Sections 144C and 153 remains unresolved at the Supreme Court level.

Shelf Drilling Ron Tappmeyer Ltd. v. ACIT\n(Intl. Taxation)
153 Taxmann.com 162 · 2023 · High Court
169
citing judgments

The time consumed in proceedings before the Dispute Resolution Panel (DRP) under Section 144C must be subsumed within the limitation period prescribed under Section 153 for the completion of assessment, meaning these timelines are not mutually exclusive.

ESPN Star Sports Mauritius S.N.C. ET Compagnie v. Union of India
388 ITR 383 · 2016 · High Court
71
citing judgments

Failure to issue a draft assessment order under Section 144C(1) makes the final assessment order illegal and beyond jurisdiction. Non-compliance with Dispute Resolution Panel (DRP) directions renders the final assessment order bad in law.

Roca Bathroom Products (P.) Ltd. v. Dispute Resolution Panel-2
127 Taxmann.com 332 · 2021 · High Court
57
citing judgments

A High Court decision is binding on subordinate authorities like the Assessing Officer. The Assessing Officer erred in not following a prior jurisdictional High Court ruling and a Madras High Court ruling.

Vodafone India Services Pvt. Ltd. v. Addl. CIT & Ors.
361 ITR 531 · 2014 · High Court
40
citing judgments

Proceedings before the Dispute Resolution Panel (DRP) are a continuation of the assessment proceedings, not an appeal. The DRP's role is to act as a correcting mechanism, providing a second review of the proposed assessment order.

CIT v. Tata Power Solar Systems Ltd.
77 Taxmann.com 326 · 2017 · High Court
25
citing judgments

An assessee can withdraw a company from the list of comparables if it was inadvertently included and is not genuinely comparable.

S.A. Builders Ltd. v. CIT(Appeals)
338 ITR 482 · 2011 · High Court
23
citing judgments

The deletion of a disallowance under Section 36(1)(iii) by the Dispute Resolution Panel (DRP) is upheld when relied upon by other judgments.

Judgments citing dispute resolution panel

M/S Toyota Kirloskar Motors (P) Ltd, Bangalore vs. The Assistant Commissioner of Income Tax Ltu Circle-1, Bangalore

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

ITA 150/BANG/2017[2012-13]Status: DisposedITAT Bangalore02 Dec 2022AY 2012-13

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

For Appellant: Sri Padam Chand Khincha, A.RFor Respondent: Sri Sunil Kumar Singh, D.R
Section 40A(2)

learned Additional Commissioner of Income Tax, Transfer Pricing-2(2), Bangalore (hereinafter referred to as "TPO" for brevity) and Honorable Dispute Resolution Panel-2 (hereinafter referred to as Honorable DRP) ("AO "TPO" and "DRP" collectively referred as "lower authorities" for brevity)-are bad in law and liable to be quashed

Roca Bathroom Products Private Limited, Chennai vs. DCIT Ltu-1, Chennai

The appeal stand partly allowed to the extent indicated in the order

ITA 2976/CHNY/2017[2013-14]Status: DisposedITAT Chennai30 Nov 2022AY 2013-14

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri N. V. Balaji (Advocate) – Ld. ARFor Respondent: Dr. S. Palanikumar (CIT) – Ld. DR
Section 143(3)Section 144C(5)Section 92C

assessment order dated 26-09-2017 passed by Ld. Assessing Officer (AO) u/s 143(3) r.w.s. 144C pursuant to the directions of Ld. Dispute Resolution Panel-2, Bengaluru (DRP) u/s 144C(5) dated 13-09-2017. The assessee carried out certain international transactions with its Associated Enterprises (AE) which were ... transfer pricing adjustment made by the AO/TPO The learned TPO and the learned AO, under the directions issued by the Hon'ble Dispute Resolution Panel ('DRP'): 2. Erred in law and on facts of the case in considering advertisement, marketing and promotion ('AMP') expenditure incurred by the Assessee wholly

Mindteck (India) Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-4(1)(1), Bangalore

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 211/BANG/2022[2017-18]Status: DisposedITAT Bangalore30 Nov 2022AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Shri K. Sankar Ganesh, D.R
Section 143(3)

orders passed by the learned Deputy Commissioner of Income-tax Transfer Pricing 2(1)(1) (Transfer Pricing Officer/ TPO); and Honorable Dispute Resolution Panel [collectively referred as "lower income tax authorities" for brevity] to the extent prejudicial to the assessee are bad in law and liable to be quashed ... Aggrieved by the adjustment proposed by AO in draft order, the assessee filed the objections before the Dispute Resolution Panel (‘DRP’) in Form 35A on 29.04.2021. The DRP vide its order dated 28.12.2021 directed certain modifications to the adjustment made by the TPO in its order under section 92CA

Astrazeneca Pharma India Limited, Bangalore vs. Deputy Commissioner of Income Tax, Ltu, Circle-1, Bangalore

In the result, the revenue appeal is dismissed and the appeal filed by the assessee is partly allowed

ITA 460/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Nov 2022AY 2011-12

Bench: Smt. Beena Pillai & Ms. Padmavathy S.It(Tp)A No. 460/Bang/2016 (Assessment Year: 2011-12)

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Manjunath Karkihalli, CIT-DR
Section 143(2)Section 143(3)Section 144CSection 144C(11)

percentage (A/B) 73.84% It is further submitted that for AY 2010-11, the Assessee had filed objections before the Dispute Resolution Panel (“DRP”) regarding the acceptance of Lotus Labs as a comparable for the relevant assessment year. The assessee submitted that the Lotus Labs had significant related party transactions ... read with section 144C of the Income Tax Act, 1961 ("Act"), in pursuance of the directions issued by the Hon'ble Dispute Resolution Panel ("Panel"), Bengaluru dated 30 December 2015 under section 144C(5) of the Act on the following grounds: On the facts and circumstances of the case

DCIT, Bangalore vs. M/S Astra Zenca Pharma India Ltd., Bangalore

In the result, the revenue appeal is dismissed and the appeal filed by the assessee is partly allowed

ITA 446/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Nov 2022AY 2011-12

Bench: Smt. Beena Pillai & Ms. Padmavathy S.It(Tp)A No. 460/Bang/2016 (Assessment Year: 2011-12)

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Manjunath Karkihalli, CIT-DR
Section 143(2)Section 143(3)Section 144CSection 144C(11)

percentage (A/B) 73.84% It is further submitted that for AY 2010-11, the Assessee had filed objections before the Dispute Resolution Panel (“DRP”) regarding the acceptance of Lotus Labs as a comparable for the relevant assessment year. The assessee submitted that the Lotus Labs had significant related party transactions ... read with section 144C of the Income Tax Act, 1961 ("Act"), in pursuance of the directions issued by the Hon'ble Dispute Resolution Panel ("Panel"), Bengaluru dated 30 December 2015 under section 144C(5) of the Act on the following grounds: On the facts and circumstances of the case

DCIT-2(2)(1), Mumbai vs. The Indian Hotels Company Ltd., Mumbai

In the result, appeal of the Assessee is partly allowed whereas the appeal of the Revenue is dismissed

ITA 3022/MUM/2016[2011-12]Status: DisposedITAT Mumbai29 Nov 2022AY 2011-12
For Appellant: Sh. Kanchan Kaushal, Sh. PratikFor Respondent: Dr. Yogesh Kamat
Section 115JSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 14ASection 36(1)(iii)Section 40Section 92C

IN THE INCOME TAX APPELLATE TRIBUNAL "K" BENCH, MUMBAI SHRI B.R. BASKARAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER The

The Indian Hotels Company Ltd., Mumbai vs. DCIT Cir. 2(2)(1), Mumbai

In the result, appeal of the Assessee is partly allowed whereas the appeal of the Revenue is dismissed

ITA 2308/MUM/2016[2011-12]Status: DisposedITAT Mumbai29 Nov 2022AY 2011-12
For Appellant: Sh. Kanchan Kaushal, Sh. PratikFor Respondent: Dr. Yogesh Kamat
Section 115JSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 14ASection 36(1)(iii)Section 40Section 92C

IN THE INCOME TAX APPELLATE TRIBUNAL "K" BENCH, MUMBAI SHRI B.R. BASKARAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER The

Shell Informaation Technology International Bv, Mumbai vs. Dy Commissioner of Income Tax (International Taxation)-4(2)(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 996/MUM/2022[2018-19]Status: DisposedITAT Mumbai28 Nov 2022AY 2018-19
Section 143(3)Section 144C(13)Section 144C(5)Section 2(24)Section 234BSection 270A

16/03/2022 u/s.143(3) r.w.s. 144C(13) of the Income Tax Act, hereinafter referred to as Act, pursuant to the directions of the ld. Dispute Resolution Panel (DRP in short) u/s.144C(5) of the Act dated 25/02/2022 for the A.Y.2018-19. 2 M/s. Shell Information Technology International B.V. 2. The assessee ... Income-tax Act, 1961 (hereinafter referred to as the "Act"), in pursuance of the directions issued by the Hon'ble Dispute Resolution Panel-2, (hereinafter referred to as the "Hon'ble DRP) on the following grounds, each of which are without prejudice to one another. On the facts and circumstances

Torrecid India Pvt. Ltd, Mumbai vs. Income Tax Circle-3(3) (1), Mumbai

Appeal of the assessee is allowed

ITA 660/MUM/2022[2017-18]Status: DisposedITAT Mumbai28 Nov 2022AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Torrecid India Private Limited Income Tax Circle-3(3)(1) Flat No. 29,30,31, Gidc, Savli, Aaykar Bhavan, Mumbai-400 Alidra, Vadodara, Vs. 020 Gujarat-391775 (Appellant) (Respondent) Pan No. Aabcl4860B Assessee By : Shri. Sagar Sawhney. Revenue By : Shri. Samuel Pitta Srar Date Of Hearing: 01.09.2022 Date Of Pronouncement : 28.11.2022

For Appellant: Shri. Sagar SawhneyFor Respondent: Shri. Samuel Pitta SRAR
Section 143(3)Section 144C(13)

against the assessment order passed by National Faceless Appeal Centre, Delhi (the ld. AO) on 16.02.2022 pursuant to the direction of Dispute Resolution Panel dated 18.01.2022 u/s.143(3) r.w.s. 144C (13) of the Income Tax Act, 1961 (the Act) wherein the transfer pricing adjustment of ₹ 99,31,763/- was made ... learned Assessing Officer (“ld. AO”) dated 16 February 2022/ learned Transfer Pricing Officer (“ld.TPO) in pursuance of the directions issued by Hon'ble Dispute Resolution Panel (“DRP”) (dated 18 January 2022) under Section 143(3) read with Section 144C(13) of the Income

Shellinformation Technology International Bv, Mumbai vs. DCIT (It) 4 (2)(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 2308/MUM/2022[2019-20]Status: DisposedITAT Mumbai28 Nov 2022AY 2019-20
Section 143(3)Section 144C(13)Section 144C(5)Section 2(24)Section 234BSection 234DSection 270A

20/07/2022 u/s.143(3) r.w.s. 144C(13) of the Income Tax Act, hereinafter referred to as Act, pursuant to the directions of the ld. Dispute Resolution Panel (DRP in short) u/s.144C(5) of the Act dated 15/06/2022 for the A.Y.2019-20. M/s. Shell Information Technology International B.V. 2. The assessee has raised ... Income-tax Act, 1961 (hereinafter referred to as the 'Act'), in pursuance of the directions issued by the Hon'ble Dispute Resolution Panel-2, (hereinafter referred to as the 'Hon'ble DRP') on the following grounds, each of which are without prejudice to one another: On the facts and circumstances

Ala Chemicals P. Ltd., Palghar vs. Dy CIT-5(1)(1), Mumbai

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

ITA 7950/MUM/2019[2015-16]Status: DisposedITAT Mumbai28 Nov 2022AY 2015-16
Section 143(3)Section 144C(13)Section 3Section 92B

read with section 144C(13) of the Income Tax Act for A.Y. 2015-16 in pursuance of the direction issued by learned Dispute Resolution Panel (DRP). 2. The assessee is aggrieved with the addition relating to the transfer pricing adjustment made by the Assessing Officer. 3. The assessee is engaged

Owens Corning Composite Materials Llc, Mumbai vs. Dy CIT (It)- Circle-3(2)(2), Mumbai

In the result, appeal by the assessee is partly allowed, in the terms aforesaid

ITA 6804/MUM/2019[2016-17]Status: DisposedITAT Mumbai28 Nov 2022AY 2016-17

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं. 6804/मुं/ 2019 ("न.व. 2016-17) Owens-Corning Composite Materials Llc C/O.Owens Cornining (India) Pvt. Ltd. 7Th Floor, Alpha Building, Hiranandani Gardens, Powai, Mumbai – 400 076. Pan:Aabco-4236-G ...... अपीलाथ" /Appellant बनाम Vs. The Deputy Commissioner Of Income-Tax (International Tax), Circle – 3(2)(2) Mumbai, Room No.X. 16Th Floor, Air India Bldg., Nariman Point,Mumbai – 400 021 ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : Shri Sandeep Bhalla ""तवाद" "वारा/Respondent By : Smt. Mahita Nair सुनवाई क" "त"थ/ Date Of Hearing : 02/09/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 28/11/2022 आदेश/ Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 30/08/2019 Passed Under Section 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 [ In Short “The Act”] For The Assessment Year 2016-17. 2 2. The Assessee In Appeal Has Raised Two Grounds. In Ground No.1 Of Appeal, The Assessee Has Assailed The Findings Of Assessing Officer In Treating Amount Received On Reimbursement Of Software Supplied By The Assessee To Its Indian Subsidiary As ‘Royalty’. In Ground No.2 Of Appeal, The Assessee Has Assailed Short Credit Of Tds.

For Appellant: Shri Sandeep BhallaFor Respondent: Smt. Mahita Nair
Section 143(3)Section 9(1)(vi)

assessee submits that the consideration received for the software is not in the nature of ‘Royalty’ as has been alleged by Dispute Resolution Panel (DRP) and the Assessing Officer. The assessee or any of its AEs has not been granted any right in the underlying copyright of the software

Tyco Fire and Security India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore

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

ITA 270/BANG/2021[2016-17]Status: DisposedITAT Bangalore28 Nov 2022AY 2016-17

Bench: Shri N. V. Vasudevan & Shri Chandra Poojariit(Tp)A No.270/Bang/2021 Assessment Year : 2016-17 Acit, M/S. Tyco Fire & Security India Private Limited, Vs. D-601, Rmz Centennial, Circle - 7(1)(1), Kundalahalli Main Road, Bengaluru. Bengaluru – 560 048. Pan : Aabct 0087 C Appellant Respondent Assessee By : Shri. Rajan Vora, Ca Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 27/11.09.2022 Date Of Pronouncement : 28.11.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. Rajan Vora, CAFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144C(13)Section 92Section 92(1)Section 92B(1)

account of determination of ALP for provision of SWD services by the Assessee to its AE. 6. The Assessee filed objections before the Disputes Resolution Panel (DRP) against the draft assessment order passed by the AO wherein the addition suggested by the TPO as adjustment consequent to determination ... Crores and the short-term capital gain / loss was reworked to be Nil. 33. The Assessee filed objections before the Dispute Resolution Panel (DRP) against the draft order of Assessment incorporating the above findings of the AO. The DRP upheld the AO’s findings and held that the series

Finastra Software Solutions (India) Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

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

ITA 268/BANG/2021[2016-17]Status: DisposedITAT Bangalore28 Nov 2022AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy S.It(Tp)A No. 268/Bang/2021 (Assessment Year: 2016-17)

For Appellant: Shri T. Suryanarayana, AdvFor Respondent: Shri Manjunath Karkihalli, CIT-DR
Section 143(3)Section 80G

outstanding receivables, the aggregate of which was subsequently reworked to Rs. 30,14,89,323/-on giving effect to the directions of the Dispute Resolution Panel (“DRP”); and (b) Disallowance of Rs. 14,17,500/- made by the Assessing Officer, being deduction claimed under Section 80G of the Income

Sr Technics Switzerland Limited, Mumbai vs. ACIT (It)-4(2)(2), Mumbai

ITA 6616/MUM/2018[2015-16]Status: DisposedITAT Mumbai25 Nov 2022AY 2015-16

Bench: Shri Vikas Awasthy & Shri Gagan Goyals.R. Technics Switzerland Limited. C/O. B-206, Citipoint, A.K. Road, Andheri (East), Mumbai-400059. Pan: Aalcs3475M ...... Appellant Vs. Acit (International Taxation), Range- 4(2) (2), Mumbai-400020. ..... Respondent Appellant By : Sh. Dhanesh Bafna / Sh. Pratik Shah Respondent By : Ms. Surabhi Sharma, Cit-Dr Date Of Hearing : 29/08/2022 Date Of Pronouncement : 25/11/2022 Order Per Gagan Goyal, A.M: This Appeal By The Assessee Is Directed Against The Order Of Acit(It-4(2)(2), Mumbai, [Hereinafter Referred To As [‘Acit’] Dated 24.09.2018 Passed Under Section 143(3) Read With Section 144(C)(13) Of The Income Tax Act, 1961 (Hereinafter Referred To As [‘The Act’] For The Assessment Year (Ay) 2015-16. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Sh. Dhanesh Bafna / Sh. Pratik ShahFor Respondent: Ms. Surabhi Sharma, CIT-DR
Section 143(3)Section 144Section 234BSection 234CSection 234DSection 245Section 271(1)(c)Section 9(1)

facts and in the circumstances of the - case and in law. the Learned Assessing Officer (Ld. AO) and Hon'ble Dispute Resolution Panel (Hon'ble DRP) erred in concluding that the Liaison Office (LO) of the Appellant constitutes a business connection of Appellant in India as per provisions of Section

Jm Morgan Stanley Securities P. Ltd, Mumbai vs. Addl CIT 4(3), Mumbai

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

ITA 7118/MUM/2010[2006-07]Status: DisposedITAT Mumbai25 Nov 2022AY 2006-07

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Sunil M. LalaFor Respondent: Ms. Vatsalaa Jha
Section 143(3)Section 144C(13)Section 144C(5)Section 14ASection 40Section 40A(2)

section 144C(13) of the Income Tax Act, 1961 (‘the Act’) pursuant to the directions dated 14/07/2010, issued by the learned Dispute Resolution Panel–II, Mumbai, (“learned DRP”) under section 144C(5) of the Act, for the assessment year 2006–07. 2. In its appeal, the assessee has raised ... case, the learned Transfer Pricing Officer (TPO) and the learned Assessing Officer (AO) have legally erred in proposing and the Hon'ble Dispute Resolution Panel (DRP) further erred in confirming the proposed addition of Rs 22,99,91,344 on account of alleged lower commission charged to Associated Enterprises namely

Infinity Retail Ltd, Mumbai vs. DCIT RG 10(1)(1), Mumbai

The appeals are partly allowed

ITA 2297/MUM/2015[2010-11]Status: DisposedITAT Mumbai23 Nov 2022AY 2010-11
For Appellant: Shri Nitesh JoshiFor Respondent: Ms. Samruddhi Dhananjay Hande
Section 143(3)Section 144C(13)Section 144C(5)Section 40

circumstances of the case and in law the Ld. AO/Learned Transfer Pricing Officer (Ld. TPO") erred in proposing and the Hon'ble Dispute Resolution Panel ("DRP") further erred in upholding the transfer pricing adjustment of Rs.59.90,822 pertaining to reimbursement of expenses paid/ received by the appellant to/from its Associated ... case and in law the Learned Assessing Officer/ Transfer Pricing Officer/ ("Ld. AO/ TPO") erred in proposing and the Hon'ble Dispute Resolution Panel ("DRP") further erred in upholding the transfer pricing adjustment of Rs.40,07,005 pertaining to reimbursement of out of pocket expenses and reimbursement of software maintenance

M/S United Spirits Limited, Bangalore vs. Joint Commissioner of Income Tax Special Range-7, Bangalore

In the result, ground 7 is allowed for statistical purposes

ITA 3091/BANG/2018[2014-15]Status: DisposedITAT Bangalore22 Nov 2022AY 2014-15

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.3091/Bang/2018 : Asst.Year 2014-2015 M/S.United Spirits Limited The Joint Commissioner Of 6Th Floor, Ub Towers, Income-Tax, Special Range-7 V. Bangalore. # 24 Vittal Mallya Road Bangalore – 560 001. Pan : Aaccm8043J. (Appellant) (Respondent)

For Appellant: Sri.Percy Pardiwala, Senior Counsel and Sri.Ankur Pai, AdvocateFor Respondent: Sri. Manjunath Karkihalli, CIT –DR
Section 115PSection 143(2)Section 143(3)Section 14ASection 234BSection 36(1)(iii)Section 92C

also proposed certain additions / disallowances on the corporate tax front. 3. Aggrieved by the draft assessment order, the assessee filed objections before the Dispute Resolution Panel (DRP). The DRP vide its directions dated 29.09.2018, disposed off the objections of the assessee. The DRP upheld the TP adjustment proposed

Red Hat India Pvt. Ltd., Mumbai vs. Addll/Jt./Dy./ACIT/ ITO, NFAC -Delhi, Delhi

In the result, the present appeal by the assessee is dismissed as withdrawn

ITA 1706/MUM/2022[2017-18]Status: DisposedITAT Mumbai21 Nov 2022AY 2017-18

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Rohit sutarFor Respondent: Ms. Vatsalaa Jha
Section 143(3)Section 144BSection 144CSection 144C(13)

144C(13) r/w section 144B of the Income Tax Act, 1961 (‘the Act’), pursuant to the directions dated 20/01/2022, issued by the learned Dispute Resolution Panel under section 144C of the Act, for the assessment year 2017–18. 2. During the hearing, at the outset, the learned Authorised Representative appearing

Triumph International (India) Private Limited, Kancheepuram vs. ACIT, Chennai

ITA 935/CHNY/2016[2011-12]Status: DisposedITAT Chennai18 Nov 2022AY 2011-12

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri S.P. Chidambaram (Advocate) -Ld. ARFor Respondent: Dr. S. Palanikumar (CIT)–Ld. DR
Section 143(3)

arises out of final assessment order dated 25.02.2015 passed u/s 143(3) r.w.s. 92CA(4) r.w.s.144C pursuant to the directions of learned Dispute Resolution Panel, Chennai [DRP] dated 22-12- 2014. The assessee carried out certain international transactions with its Associated Enterprises (AE) which were subjected to determination