“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

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

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

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

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

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

Spencer Stuart International B.V. Tax, Mumbai vs. The ACIT (It) -4(2)(2), Mumbai

In the result, appeal by the assessee is allowed for statistical purpose

ITA 514/MUM/2022[2019-20]Status: DisposedITAT Mumbai04 Nov 2022AY 2019-20

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Mukesh Butani a/wFor Respondent: Shri Lovish Kumar

Section 143(3)Section 144C(13)Section 144C(5)Section 195Section 9(1)(vii)

section 144C(13) of the Income Tax Act, 1961 (“the Act”), pursuant to the directions dated 05/01/2022, issued by the learned Dispute Resolution Panel (“learned DRP”) under section 144C(5) of the Act, for the assessment year 2019–20. Spencer Stuart International B.V. ITA No.514/Mum./2022 2. In its appeal ... Assistant Commissioner of Income- tax, (International Taxation) 4(2)(2) Mumbai [Assessing Officer] on the basis of the directions of the Dispute Resolution Panel [DRP] for the aforesaid assessment year on the following among other grounds: A. Taxability of Search Fees 1. That on the facts and circumstances

Spencer Stuart International B.V., Mumbai vs. ACIT (It) 4(2)(2), Mumbai

In the result, appeal by the assessee is allowed

ITA 318/MUM/2022[2018-19]Status: DisposedITAT Mumbai04 Nov 2022AY 2018-19

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Mukesh Butani a/wFor Respondent: Shri Lovish Kumar

Section 143(3)Section 144C(13)Section 144C(5)Section 195Section 9(1)(vii)

section 144C(13) of the Income Tax Act, 1961 (‘the Act’), pursuant to the directions dated 24/11/2021, issued by the learned Dispute Resolution Panel (“learned DRP”) under section 144C(5) of the Act, for the assessment year 2018–19. 2. In this appeal, assessee has raised following grounds: Spencer Stuart ... Assistant Commissioner of Income-tax, (International Taxation) - 4(2)(2), Mumbai [Assessing Officer] on the basis of the directions of the Dispute Resolution Panel [DRP] for the aforesaid assessment year on the following among other grounds: A. Taxability of Search Fees 1. That on the facts and circumstances

Cma Cgm Sa, Mumbai vs. Asstt CIT (International Taxationa)-2(1)(1), Mumbai

In the result, additional grounds of appeal filed by the assessee are allowed for statistical purpose

ITA 1013/MUM/2021[2017-18]Status: DisposedITAT Mumbai03 Nov 2022AY 2017-18

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Nikhil TiwariFor Respondent: Shri Lovish Kumar

Section 143(3)Section 144C(13)Section 144C(5)Section 234BSection 270ASection 44B

section 144C(13) of the Income Tax Act, 1961 („the Act‟), pursuant to the directions dated 25/02/2021, issued by the learned Dispute Resolution Panel (“learned DRP”) under section 144C(5) of the Act, for the assessment year 2017–18. 2. In this appeal, assessee has raised following grounds

Clariant Chemicals (India) Ltd, Thane vs. Deputy Commissioner of Income Tax, Circle - 1(1)(1), Mumbai

In the result, appeal of the assessee is dismissed as withdrawn

ITA 82/MUM/2018[2012-13]Status: DisposedITAT Mumbai03 Nov 2022AY 2012-13

Bench: Shri Amit Shukla, Hon'Ble & Shri Gagan Goyal, Hon'Blea.Y. 2012-13 Clariant Chemicals (India) Limited V. Dy. Commissioner Of Reliable Tech Park, Behind Reliable Income Tax, Plaza, Thane-Belapur Road, Airoli, Circle-1(1)(1),Mumbai. Navi Mumbai 400 078. Pan: Aaacc5602P (Appellant) (Respondent)

For Appellant: Ms. Swati PatelFor Respondent: Dr. Yogesh Kamat

Section 143(3)

Mumbai u/s 143(3) r.w.s 144C of the Income Tax Act, 1961 (in short „the Act‟) in pursuance of the directions of the Dispute Resolution Panel dated 22.09.2017 for Assessment Year 2012-13. 2 Clariant Chemicals (India) Ltd. 2. At the outset, ld. Counsel for assessee stated that the assessee

Aquity Solutions India Pvt.Ltd(Formerly Known As Mmodal Global Services Pvt. Ltd, Mumbai vs. Dy.Ci.T.15(1) (1), Mumbai

In the result, appeal by the assessee is partly allowed

ITA 713/MUM/2022[2017-18]Status: DisposedITAT Mumbai02 Nov 2022AY 2017-18

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Harsh ShahFor Respondent: Ms. Samruddhi D. Hande

Section 144BSection 144C(13)Section 144C(3)Section 144C(5)

section 144B of the Income Tax Act, 1961 (“the Act”) for the assessment year 2017–18, pursuant to the directions issued by the Dispute Resolution Panel (DRP)–1, Mumbai (“learned DRP”), under section 144C(5) of the Act. Aquity Solutions India Pvt. Ltd. (Formerly known as Mmodal Global Services ... case and in law, the learned Transfer Pricing Officer (TPO)/ the learned Assessing Officer (AO) under directions of the Hon'ble Dispute Resolution Panel („DRP') erred in making an addition of Rs. 1,26,43,352/- to the total income of the Appellant on account of interest chargeable on trade

M/S. Ig Infotech (India) Private Limited, Bengaluru vs. Assistant Commissioner of Income-Tax, Circle-3(1)(1), Bengaluru

In the result, the appeal of the assessee is allowed

ITA 204/BANG/2022[2017-18]Status: DisposedITAT Bangalore01 Nov 2022AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Nageswar Rao, A.RFor Respondent: Shri Praveen Karanth, D.R

Section 143(3)Section 144BSection 144C(13)Section 92C

Pricing Officer (-the learned TPO") in his order passed under section 92CA(3) of the Act and subsequently confirmed by the Hon'ble Dispute Resolution Panel ("Honble DRP"). Each of the ground is referred to separately. which may kindly be considered independent of each other. That on the facts

Howden Solyvent (India) Pvt. Ltd., Chennai vs. DCIT, Chennai

Appeal stands partly allowed in terms of our above order

ITA 732/CHNY/2015[2010-11]Status: DisposedITAT Chennai31 Oct 2022AY 2010-11

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

For Appellant: Shri Darpan Kripalani (Advocate) &For Respondent: Dr. S. Palani Kumar- CIT-DR

Section 143(3)Section 144C(5)Section 234BSection 43B

passed by Ld. Assessing Officer, Chennai (AO) u/s 143(3) r.w.s. 144C(13) r.w.s. 92CA(3) pursuant to the directions of Learned Dispute Resolution Panel, Chennai (DRP) u/s. 144C(5) of the Act dated 19-11-2014. The assessee carried out certain international transactions with its Associated Enterprises (AE) which ... assessee read as under: - 1. That on the facts and in the circumstances of the case the Ld AO and the Hon’ble Dispute Resolution Panel (Honble DRP) erred in not confirming the arms length nature of the international transaction of payment of management service fee without considering the fact

Gabriel India Limited, 29Th Milestone vs. The Deputy Commissioner of Income Tax, Circle 5(1)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 185/MUM/2022[2014-15]Status: DisposedITAT Mumbai31 Oct 2022AY 2014-15

Bench: Shri.Ri Om Prakashri. Kant & Shri Sandeep Singh Karhailआ.अ.सं.185/मुं/2022 िन.व.2014-15

For Appellant: Shri.Viral Shah & Kalpesh UnadkatFor Respondent: Shri Manish Ajudia - Sr.AR

Section 143(3)Section 43(1)Section 80I

learned CIT DR vehemently supported the orders of the lower authorities. She specifically referred to the direction of the dispute resolution panel wherein the decision of the honourable Bombay High Court in decision of special bench in case of Reliance Indusres Limited , has been sent back by the honourable Supreme

M/S Essity India Pvt Ltd (Formrly Known As M/S Bsn Medical Pvt Ltd), Mumbai vs. Asst CIT 12 (1)(2), Mumbai

Appeal of the assessee is dismissed having been become infructuous

ITA 7007/MUM/2019[2015-16]Status: DisposedITAT Mumbai31 Oct 2022AY 2015-16

Bench: Shri Kuldip Singh & Shri Gagan Goyalassessment Year: 2015-16

For Appellant: NoneFor Respondent: Shri Samruddhi Dhanjay Hande, D.R

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

appeal sought to set aside the impugned order dated 09.09.2019 passed by the Assessing Officer (AO) inconsonance with the order passed by the Dispute Resolution Panel (DRP) dated 03.07.2019 and order passed by Transfer Pricing Officer (TPO) under section 2 M/s. Essity India Pvt. Ltd. (Formerly known

Aker Powergas P. Ltd, Mumbai vs. DCIT RG 15(1)(1), Mumbai

ITA 2213/MUM/2017[2012-13]Status: DisposedITAT Mumbai31 Oct 2022AY 2012-13

Bench: Shri Kuldip Singh & Shri Gagan Goyalassessment Year: 2012-13

For Appellant: Shri Ketan Ved, A.RFor Respondent: Ms. Samruddhi Dhananjay Hande, D.R

Section 143(3)Section 144BSection 144C(3)Section 92C

appeal sought to set aside the impugned order dated 31.01.2012 passed by the Assessing Officer (AO) inconsonance with the order passed by the Dispute Resolution Panel (DRP) dated 23.12.2016 and order passed by Transfer Pricing Officer (TPO) under section 92CA(3) dated 31.01.2017 under 2 M/s. Aker Powergas ... short ‘the Act’) qua the assessment year 2012-13 on the grounds inter-alia that :- “1.1 The learned DCIT / Dispute Resolution Panel ("DRP") has erred in upholding an adjustment of Rs. 45,600,001 in law and on facts, by determining the arm's length price ('ALP’) of the international

ACIT 10(2)(1), Mumbai vs. Jacob Engineering India P.Ltd, Mumbai

ITA 3700/MUM/2016[2010-11]Status: DisposedITAT Mumbai31 Oct 2022AY 2010-11

Bench: Shri Kuldip Singh & Shri Om Prakash Kantassessment Year: 2010-11 Acit-10(2)(1), M/S. Worley India Pvt. R.No.216-A, Ltd. (Formerly Known As Aayakar Bhavan, Jacobs Engineering India M.K. Road, Pvt. Ltd.), Vs. Mumbai - 400020 Ramkrishna Mandir Road, Kondivita, Andheri (East), Mumbai – 400 059 Pan: Aaach0456J (Appellant) (Respondent)

For Appellant: Shri Niraj Sheth, A.R. &For Respondent: Dr. Yogesh Kamat, D.R

Section 143(3)Section 144BSection 144C(3)Section 92C

objections sought to set aside the impugned order dated 16.04.2014 passed by the Assessing Officer (AO) inconsonance with the order passed by the Dispute Resolution Panel (DRP) dated 22.01.2014, order passed by Transfer Pricing Officer (TPO) under section 92CA(3) dated 22.01.2014 under section 143(3) read with section 144C

Nimbus Communications Ltd, Mumbai vs. Asst CIT RG 16(1), Mumbai

In the result, appeal is dismissed for above reasons

ITA 2218/MUM/2017[2012-13]Status: DisposedITAT Mumbai28 Oct 2022AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Nimbus Communication Ltd Nimbus Centre, Oberioa Acit Rg16(1) Complex, Mumbai Vs. Andheri(W), Mumbai - 400 053 (Appellant) (Respondent) Pan No. Aaacn3947L Assessee By : None Revenue By : Shri. Shyam Prasad. (Cit Dr) Date Of Hearing: 11.10.2022. Date Of Pronouncement : 28.10.2022. O R D E R

For Appellant: NoneFor Respondent: Shri. Shyam Prasad. (CIT DR)

Section 143Section 143(3)Section 144CSection 14ASection 92Section 92ASection 92C

Commissioner of Income Tax, Range-16(1) Mumbai, in pursuance of direction issued under section 144C (5) of the Act by the learned Dispute Resolution Panel 2, Mumbai. The assessee has raised following grounds of appeals :- “The appellant objects to the order dated 31st January, 2017 passed under Section ... Income Tax, Range 16 (1), Mumbai [Assessing Officer] in pursuance of the direction issued under Section 144C of the Act by the learned Dispute Resolution Panel - 2, Mumbai (DRP) on the following amongst other grounds:- 1. The transfer Pricing proceedings initiated by the Assessing Officer under Section 92CA

Bny Mellon Technology Private Limited, Chennai vs. DCIT Corporate Circle 2(2), Chennai

The appeal stand partly allowed in terms of our above order

ITA 712/CHNY/2018[2010-11]Status: DisposedITAT Chennai27 Oct 2022AY 2010-11

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

For Appellant: Shri N.V. Balaji (Advocate)-Ld. ARFor Respondent: Ms. Ann Mary Baby – Ld. CIT-DR

Section 115JSection 14A

Manoj Kumar Aggarwal (Accountant Member) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2010-11 arises out of directions of Ld. Dispute Resolution Panel-2, Bengaluru dated 27.12.2017. The sole issue that arises in the appeal is disallowance u/s 14A under normal provisions as well as while computing Book

Keller Ground Engineering India Private Ltd, Chennai vs. ACIT, Corporate Circle 4(2), Chennai

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

ITA 114/CHNY/2018[2012-13]Status: DisposedITAT Chennai21 Oct 2022AY 2012-13

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri Sriram Seshadhri, CAFor Respondent: Shri D. Hema Bhupal, JCIT

Section 143(1)Section 143(2)Section 143(3)Section 144CSection 156Section 92C

relevant discussion, facts and legal position reads as under:- 9. Section 144C of the Act with the marginal note "Reference to Dispute Resolution Panel" provides through sub-section (1) of section 144C that: "The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance

Integra Software Services P. Ltd., Chennai vs. DCIT, Pondicherry

The appeal stands partly allowed in terms of our above order

ITA 736/CHNY/2017[2012-13]Status: DisposedITAT Chennai21 Oct 2022AY 2012-13

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

For Appellant: Shri N. Arjunraj (CA) for Shri. S. Sridhar (Advocate) – Ld. ARFor Respondent: Shri R. Bhoopathi (JCIT) / Shri. Kumar Ajeet Ld. CIT-DR

Section 143(3)Section 144C(5)Section 14ASection 195Section 40Section 43(5)Section 9(1)(vii)Section 92C

final assessment order dated 15.02.2017 passed by Ld. Assessing Officer (AO) u/s 143(3) r.w.s. 144C(5) pursuant to the directions of Ld. Dispute Resolution Panel-1, Bengaluru (DRP) u/s 144C(5) dated 30.12.2016. The Ld. Transfer Pricing Officer-2(1), Chennai (TPO) has determined Arm’s Length Price

Dover India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

In the result, appeal of the Assessee is partly allowed

ITA 460/BANG/2022[2017-18]Status: DisposedITAT Bangalore21 Oct 2022AY 2017-18

Bench: Shri N. V. Vasudevan & Shri Chandra Poojariit(Tp)A No.460/Bang/2022 Assessment Year : 2017-18 M/S. Dover India Private Limited, Vs. Dcit, Bagmane Laurel, 1St Floor, Circle – 2(1)(1), Block C, Bagmane Tech Park, Bengaluru. C. V. Raman Nagar, Bengaluru – 560 093. Pan : Aaaci 3920 N Appellant Respondent Assessee By : Shri. Chavali Narayanan, Ca Revenue By : Capt. Pradeep Arya, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 03.10.2022 Date Of Pronouncement : 21.10.2022 O R D E R Per N. V. Vasudevanthis Appeal By The Assessee Is Directed Against The Final Order Of Assessment Dated 29.03.2022 Of National Faceless Assessment Centre, Delhi, (Hereinafter Referred To As The Assessing Officer, “Ao” In Short) Passed U/S.143(3) Read With Section 144C(13) Of The Income Tax Act, 1961 (Act) In Relation To Assessment Year 2017-18. 2. The Assessee In Engaged In The Business Of Providing Software Development Services (Swd Services), To Its Wholly Owned Holding Company. In Terms Of The Provisions Of Sec.92-A Of The Act, The Assessee

For Appellant: Shri. Chavali Narayanan, CAFor Respondent: Capt. Pradeep Arya, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144C(13)Section 92Section 92ASection 92B(1)Section 92CSection 92C(2)Section 92F

passes a draft order of assessment against which, the Assessee has a right to file objections before the Dispute Resolution Panel (DRP) u/s.144C of the Act. Under section 144C(5), the Dispute Resolution Panel (DRP) shall issue the directions, as it thinks fit, for the guidance ... account of determination of ALP for provision of SWD services by the Assessee to its AE. 7. 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 to ALP was added

Mfx Infotech Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle- 4(1)(2), Bangalore

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

ITA 251/BANG/2021[2016-17]Status: DisposedITAT Bangalore21 Oct 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S.It(Tp)A No. 251/Bang/2021 (Assessment Year: 2016-17)

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Manjunath Karkihalli, CIT-DR

Section 133(6)Section 143(3)Section 144B

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

M/.S Synamedia India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 6(1)(2), Bangalore

In the result, the appeal filed by assessee stands allowed in respect of the issues argued and considered hereinabove

ITA 2595/BANG/2019[2015-16]Status: DisposedITAT Bangalore21 Oct 2022AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 2595/Bang/2019 Assessment Year : 2015-16 M/S. Synamedia India Pvt. Ltd., Block 9A & 9B, The Deputy Pritech Park, Commissioner Of Survey No. 51-64/4, Income Tax, Sarjapur Outer Ring Circle – 6(1)(2), Road, Bengaluru. Vs. Bellandur Village, Bengaluru – 560 103. Pan: Aaccn1140K Appellant Respondent Assessee By : Shri Ankur Pai, Advocate : Shri Praveen Karanth, Revenue By Cit-Dr Date Of Hearing : 28-07-2022 Date Of Pronouncement : 21-10-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 29/10/2019 Passed By The Ld.Dcit, Circle – 6(1)(2), Bangalore For A.Y. 2014-15 On Following Grounds Of Appeal:

For Appellant: Shri Ankur Pai, Advocate

Section 143(2)

banking and financial services and insurance sector and also as R&D operations and patents and hence not functionally comparable. However, Ld. Dispute Resolution Panel (“DRP”) observed that this company is only engaged in software development and related services as seen from its financials. Therefore, the plea of the assessee

Ingredion India P.Ltd, Navi Mumbai vs. ITO 15(2)(1), Mumbai

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

ITA 2156/MUM/2017[2012-13]Status: DisposedITAT Mumbai20 Oct 2022AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm The Income Tax Officer Ingredion India Pvt. Ltd 15(20)(1) 1605 Rupa Solitaire, Millennium Business Park, 2Nd Floor, Aaykar Bhavan, Vs. Thane, Belapur Rd, Mahape, M.K.Road, Navi Mumbai- 400 710 Mumbai- 400 020 (Appellant) (Respondent) Pan No. Aaecc1920C Assessee By : Shri. Ketan Ved. Revenue By : Ms. Samruddhi D Hande, Sr Ar Date Of Hearing: 27.07.2022. Date Of Pronouncement: 20.10.2022. O R D E R

For Appellant: Shri. Ketan VedFor Respondent: Ms. Samruddhi D Hande, SR AR

Section 143(3)Section 144CSection 271Section 92CSection 92C(1)Section 92d

allowed in A.Y. 2012- 13. Transfer Pricing: 1. The learned Assessing Officer/ Transfer Pricing Officer (‘TPO’) under the directions of the Hon’ble Dispute Resolution Panel (DRP), erred in making an upward adjustment of ₹ 1,52,62,664/- to the total income of the Appellant, under section 92CA ... learned TPO) was made. Consequent, to that draft assessment order was passed on 14/03/2016. 06. Assessee filed objection before the learned Dispute Resolution Panel who passed its direction on 28/12/2016 confirming the action of the learned TPO. 07. Accordingly, the assessment order dated 25/01/2017 was passed wherein TPO adjustment

Lloyds Offshore Global Services Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-4(1)(1), Bangalore

In the result, the appeals for AYs 2015-16 and 2016-17 are partly allowed

ITA 194/BANG/2021[2016-17]Status: DisposedITAT Bangalore20 Oct 2022AY 2016-17

Bench: Smt Beena Pillai. & Ms. Padmavathy S

For Appellant: Shri Chavali Narayan, AdvocateFor Respondent: Shri Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 143(3)

Assessing Officer ("AO") incorporated the above TP adjustment in the draft assessment order. Aggrieved, the Assessee filed its objections before the Dispute Resolution Panel ("DRP"). The AO passed the final assessment order incorporating a TP adjustment of Rs.3,80,67,944 after giving effect to the DRP directions. Aggrieved