“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

Mega Soft Limited, Chennai vs. DCIT, Chennai

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

ITA 733/CHNY/2017[2012-13]Status: DisposedITAT Chennai21 Sept 2022AY 2012-13

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.733/Chny/2017 िनधा"रण वष" /Assessment Year: 2012-13 M/S.Mega Soft Ltd., V. The Dy. Commissioner – No.85, Kutchery Road, Of Income Tax, Mylapore, Chennai-600 004. Corporate Circle-4(1), Chennai. [Pan: Aabcm 8933 A] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.M.Muraleedhara Reddy,Ca & Mr.Nagaprasad, Ca ""यथ" क" ओर से /Respondent By : Dr.S.Palani Kumar, Cit सुनवाई क" तारीख/Date Of Hearing : 28.07.2022 घोषणा क" तारीख /Date Of Pronouncement : 21.09.2022

For Respondent: Dr.S.Palani Kumar, CIT

Section 144(5)Section 144C(13)Section 92B

final Assessment Order passed by the AO u/s.144C(13) of the Income Tax Act, 1961 dated 31.01.2017, in pursuant to directions of the Dispute Resolution Panel-2, Bengaluru, u/s.144(5) of the Income Tax Act, 1961 dated 26.12.2016 and pertains to assessment year 2012-13. 2. The assessee has raised ... following grounds of appeal: 1. The Assessing Officer (AO) ' Dispute Resolution Panel (DRP) erred in making upward adjustment in Arm's Length Price (ALP). M/s.Mega Soft Ltd. :: 2 :: 2. The AO/DRP erred in rejecting the Comparable Uncontrolled Price (CUP) method in the current year without passing a reasoned order, even

Ntt Asia Pacific Holdings Pte.Ltd Formerly Known As Dimension Data Asia Pacific Pte. Ltd, Mumbai vs. The Assistant Commissioner of Income Tax(International Tax) 2(1) (2), Mumbai

In the result, appeal by assessee is partly allowed

ITA 1781/MUM/2022[2019-20]Status: DisposedITAT Mumbai21 Sept 2022AY 2019-20

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.1781/मुं/2022 ("न.व. 2019-20) Ntt Asia Pacific Holdings Pte Ltd. (Formerly Known As Dimension Data Asia Pacific Pte. Ltd.) C/O. Dhruva Advisors Llp 1101 & 1102, 11Th Floor, One World Centre, Tower 2B, 841 Senapati Bapat Marg, Elphinstone Road, Mumbai 400 013. Pan: Aadcd – 4348-L ...... अपीलाथ" /Appellant बनाम Vs. The Asstt. Commissioner Of Income Tax (International Taxation) 2(1)(2), Room No.1612, 16Th Floor, Air India Building, Nariman Point, Mumbai 400 021. ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : Shri Sunil Moti Lala ""तवाद" "वारा/Respondent By : Shri Soumendu Kumar Dash सुनवाई क" "त"थ/ Date Of Hearing : 08/09/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 21/09/2022 आदेश/ Order

For Appellant: Shri Sunil Moti LalaFor Respondent: Shri Soumendu Kumar Dash

Section 143(3)

subsidiary in accordance with Business Support Agreement dated 1st April,2014 ( Page 11 to 22 of paper book). The Assessing Officer and the Dispute Resolution Panel (DRP) held that the amount charged by the assessee for providing such services fall within the meaning of FTS, and the conditions necessary

Trhiruvananthapuram Road Development Company Ltd., Mumbai vs. Dy CIT 14 (3)91), Mumbai

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

ITA 7600/MUM/2019[2015-16]Status: DisposedITAT Mumbai21 Sept 2022AY 2015-16

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Trhiruvananthapuram Road Dy. Cit 14(3)(1) Development Company Ltd. Aaykar Bhavan, The Il & Fs Financial Centre Plot C022 G Block Bkc Bandra M.K. Road, Vs. East, Mumbai-400 020 Mumbai-400 051 (Appellant) (Respondent) Pan No. Aacct0547J Assessee By : Shri Bhupal Rapelli, Ar Revenue By : Ms Vatsalaa Jha, Cit Dr Date Of Hearing: 08.09.2022 Date Of Pronouncement : 21.09.2022

For Appellant: Shri Bhupal Rapelli, ARFor Respondent: Ms Vatsalaa Jha, CIT DR

Section 143Section 144CSection 92BSection 92C

read with Section 144C (13) of The Income Tax Act 1961 (The Act) on 14 October 2019 as per directions of The Dispute Resolution Panel – 2, Mumbai (The Learned DRP) dated 26/9/19 determining the total income of the assessee at ₹ 105,557,280/– against the returned loss ... those are not in dispute before us, therefore, facts related thereto are not discussed here. 07. Assessee preferred objections before the learned dispute resolution panel. The directions were issued on 26/9/2019. On the issue of applicability of transfer pricing provisions, it rejected the contention of the assessee that the transfer

Spica Elastica Pvt. Ltd, Mumbai vs. National Faceless Assessment Centre, Delhi

In the result, appeal of the assessee is allowed

ITA 747/MUM/2022[2017-18]Status: DisposedITAT Mumbai20 Sept 2022AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Spica Elastica Pvt. Ltd National Faceless Assessment 477, Chandra Chowk Seth Centre Mooljee Jaitha Cloth Market, Vs. Shaik Memon Street, Kalbadevi, Delhi Mumbai-400 002 (Appellant) (Respondent) Pan No. Aaacs6153K Assessee By : Shri Bhavin Shah, Ar Revenue By : Shri Samuel Pitta, Dr Date Of Hearing: 08.09.2022 Date Of Pronouncement : 20.09.2022 O R D E R Per Prashant Maharishi, Am:

For Appellant: Shri Bhavin Shah, ARFor Respondent: Shri Samuel Pitta, DR

Section 143Section 144BSection 144CSection 92C

made transfer pricing adjustment of Rs. 219,00,415/– and not restricted to Rs. 44,70,673/– as directed by the learned Dispute Resolution Panel as per the remand report of the TPO dated 3rd February, 2022. 02. Assessee is a company engaged in manufacturer of quality elastic narrow fabrics ... current year loss was higher than the transfer pricing adjustment. 05. Assessee aggrieved with the assessment order preferred objection before the learned dispute resolution panel. Assessee submitted that it could not represent its case before the learned transfer-pricing officer for the certain reasons and submitted a detailed paper book

Sai Shipping Company Pvt Ltd, Mumbai vs. Income Tax Officer/NFAC, Delhi

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

ITA 427/MUM/2022[2012-13]Status: DisposedITAT Mumbai20 Sept 2022AY 2012-13

Section 115JSection 139Section 139(1)Section 142Section 143Section 143(3)Section 144BSection 147Section 148

r.w.s. 144C(13) read with section 144B of the Act in pursuance of directions given by Ld Dispute Resolution Panel (DRP). 2. The facts relating to the case are that the assessee is engaged in the business of Shipping Charter Services, Shipping Agencies and Ship Management Services. The original assessment ... matter relating to international transactions to the Transfer Pricing Officer. After passing of draft assessment order, the assessee filed its objections to Ld Dispute Resolution Panel. After receiving directions from Ld DRP, the AO determined the total income under the normal provisions of the Act at Rs.4.72 crores and book

Etisalat Software Solutions Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

In the result, the appeal is allowed for statistical purposes

ITA 240/BANG/2022[2017-18]Status: DisposedITAT Bangalore20 Sept 2022AY 2017-18

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

For Appellant: Shri Bharadwaj Sheshadri, CAFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 143(3)Section 92BSection 92D

Persistent Systems Ltd., 8.14. Tata Elxsi Ltd., and 8.15. Threesixty Logica Testing Services Pvt. Ltd. 9. The directions of the Dispute Resolution Panel constitute a non- speaking” 3. The assessee is a subsidiary of Emirates UAE and is engaged in the provision of software development services to its Associated Enterprise

Sulzer Pumps India Pvt Ltd., Mumbai vs. Dy CIT Circle-15 (3)(2), Mumbai

Accordingly, appeal of assessee is partly allowed

ITA 7318/MUM/2019[2015-16]Status: DisposedITAT Mumbai16 Sept 2022AY 2015-16

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm The Dy. Commissioner Of Sulzer Pumps India Pvt Ltd. Income Tax, Circle 15(3)(2), Plot No.9, Midc, Digha, Room No. 451, Aayakar Thane- Belapur Road, Navi Vs. Bhavan, Maharshi Karve Mumbai-400 708 Road, Mumbai-400 020 (Respondent) (Appellant) Pan No. Aaack2238F Assessee By : Shri V. Shridharan & Ms. Manasi C, Ar Revenue By : Shri C T Mathew, Dr Date Of Hearing: 17.06.2022 Date Of Pronouncement : 16.09.2022

For Appellant: Shri V. Shridharan &For Respondent: Shri C T Mathew, DR

Section 143(3)Section 9(1)(vii)Section 92C

Commissioner of Income-Tax, Transfer Pricing, 4(1)(1), Mumbai (the learned Transfer Pricing Officer) pursuant to the direction issued by the Learned Dispute Resolution Panel, No. II, Mumbai (the learned Dispute Resolution Panel) on 25.09.2019. 02. The assessee has raised following grounds:- “Being aggrieved by the order ... learned DCIT, Circle - 15(3)(2), Mumbai, (AO'), read with the order of the learned Dispute Resolution Panel (DRP'), Mumbai, the assessee begs to prefer the present appeal on the following grounds: A. Grounds relating to additions other than Transfer Pricing Adjustments 1. That on the facts

M/S. Te Connectivity Services India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore

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

ITA 191/BANG/2022[2017-18]Status: DisposedITAT Bangalore16 Sept 2022AY 2017-18

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sit(Tp)A No.191/Bang/2022 Assessment Year : 2017-18 M/S. Te Connectivity Services India Private Vs. National Faceless Assessment Centre, Limited, Delhi. 59/2, 1St Floor, Gurudas Heritage, Block-B, 100 Feet Ring Road, Banashankari 2Nd Stage, Bengaluru – 560 070. Pan: Aafct 3474 R Appellant Respondent Assessee By : Shri. Sriram Seshadri, Ca Revenue By : Dr. Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 14.09.2022 Date Of Pronouncement : 16.09.2022 O R D E R Per N. V. Vasudevan:

For Appellant: Shri. Sriram Seshadri, CAFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

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

time of hearing, learned Counsel for the assessee submitted that if some of the comparable companies that remain after the order of the Dispute Resolution Panel (DRP) are excluded then he would not press for adjudication of other grounds with regard to determination of Arm’s Length Price. Accordingly

Grundfos Pumps India Private Limited, Chennai vs. DCIT, Chennai

The appeal stands partly allowed

ITA 39/CHNY/2017[2012-13]Status: DisposedITAT Chennai15 Sept 2022AY 2012-13

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

For Appellant: Shri S.P. Chidambaram (Advocate) – Ld. ARFor Respondent: Shri S. Palanikumar (CIT) – Ld. DR

Section 143(3)Section 144C(5)

Deputy Commissioner of Income Tax, Corporate Circle-(2)1, Chennai (AO) u/s 143(3) r.w.s. 144C(13) pursuant to the directions of learned Dispute Resolution Panel-2, Bengaluru dated 17.10.2016 u/s 144C(5) of the Act. 2.2 The assessee, vide petition dated 27.07.2022, seek permission to withdraw Transfer Pricing grounds

Grundfos Pumps India Private Limited, Chennai vs. DCIT Corporate Circle 2(1), Chennai

The appeal stands partly allowed

ITA 3088/CHNY/2017[2013-14]Status: DisposedITAT Chennai15 Sept 2022AY 2013-14

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

For Appellant: Shri S.P. Chidambaram (Advocate) – Ld. ARFor Respondent: Shri S. Palanikumar (CIT) – Ld. DR

Section 143(3)Section 144C(5)

Metric Stream Infotech (India) Private Limited, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-4(1)(2), Bangalore

In the result, the appeal is partly allowed

ITA 314/BANG/2022[2010-11]Status: DisposedITAT Bangalore15 Sept 2022AY 2010-11

Bench: Shri N.V. Vasudevan, Vice Preseident & Ms. Padmavathy S

For Appellant: Shri Padam Chand Khincha, CAFor Respondent: Shri Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

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

incorporated by the TPO in the draft Order of Assessment. The assessee filed objection to the draft Assessment Order before Dispute Resolution Panel (DRP) u/s.144C of the Act. The DRP gave certain directions dated 29.12.2004 to the TPO. Consequent to the directions of the DRP, the transfer pricing adjustment stood ... incorporated in the draft order of Assessment by the AO. The assessee filed objection to the draft Assessment Order before Dispute Resolution Panel (DRP) u/s.144C of the Act. The DRP gave certain directions dated 29.12.2004 to the TPO. Consequent to the directions of the DRP, the transfer pricing adjustment stood

Hsbc Professional Services (I) P. Ltd, Mumbai vs. DCIT RG 8(2), Mumbai

ITA 8823/MUM/2011[2006-07]Status: DisposedITAT Mumbai13 Sept 2022AY 2006-07

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2006-07 Jcit-8(2), (Osd), M/S Hsbc Professional Services Room No. 216-A, Aayakar (India) Pvt. Ltd., Bhavan, M.K. Road, Vs. Kamla Bhavan, Swami Nityanand Mumbai-400020. Marg, Andheri (East), Mumbai-400069. Pan No. Aabch 0705 R Appellant Respondent Assessment Year: 2006-07 Hsbc Professional Services The Deputy Commissioner Of (India) Private Limited, Income-Tax Range 8(2), 6Th Floor, Shiv Building, Cts Vs. Mumbai. No. 139 & 140B, Sahar Road, Vile Parle (East), Mumbai-400057. Pan No. Aabch 0705 R Appellant Respondent Assessee By : Mr. Niraj Sheth, Ar Revenue By : Mr. V.K. Agarwal, Dr Date Of Hearing : 01/07/2022 Date Of Pronouncement : 13/09/2022

For Appellant: Mr. Niraj Sheth, ARFor Respondent: Mr. V.K. Agarwal, DR

Section 92CSection 92C(2)Section 92D

object , against which the assessee did not chose to object , against which the assessee did not chose to object before the Ld. Dispute Resolution Panel (DRP), and therefore after Dispute Resolution Panel (DRP), and therefore after Dispute Resolution Panel (DRP), and therefore after expiry of period prescribed for objecting before

DCIT RG 8(2) (OSD), Mumbai vs. Hsbc Professional Services (I) P. Ltd, Mumbai

ITA 8753/MUM/2011[2006-07]Status: DisposedITAT Mumbai13 Sept 2022AY 2006-07

For Appellant: Mr. Niraj Sheth, ARFor Respondent: Mr. V.K. Agarwal, DR

Section 92CSection 92C(2)Section 92D

Biocon Biologics Limited (Formerly Known As Biocon Biologics India Limited) (Successor to Biocon Research Limited), Bangalore vs. The Deputy Commissioner of Income Tax, Circle-1(1)(1), Bangalore

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

ITA 299/BANG/2022[2017-18]Status: DisposedITAT Bangalore13 Sept 2022AY 2017-18

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm It(Tp)A No.299/Bang/2022 : Asst.Year 2017-2018 M/S.Biocon Biologics Limited The Deputy Commissioner Of (Formerly Known As Biocon Income-Tax, Circle 1(1)(1) V. Biologics India Limited) Bengaluru. Ground Floor, Tower 3, Semicon Park, Hosur Road, Electronics City S.O. Bangalore South – 560 100. Pan : Aagcb7796M. (Appellant) (Respondent) Appellant By : Sri.Padam Chand Khincha, Ca Respondent By : Sri.Manjunath Karkihalli, Cit-Dr Date Of Pronouncement : 13.09.2022 Date Of Hearing : 06.09.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 26.02.2022 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2017-2018. 2. The Brief Facts Of The Case Are As Follows: The Assessee, Namely, Biocon Biologics Limited [Successor. To Biocon Research Limited With Appointed Date 01.04.2019] Is Engaged In The Carrying Out Research & Development ("R & D") Of Drugs & Drug Delivery Systems. For The Relevant Assessment Year ("Ay") 2017-18, The Return Of Income Was Filed On 30.11.2017, Declaring `Nil’ Income Under The Normal Provisions Of The I.T.Act & Book Losses As 2 It(Tp)A No.299/Bang/2022. M/S.Biocon Biologics Limited Per The Provisions Of Section 115Jb Of The I.T.Act. After Considering The Taxes Deducted At Source, The Assessee Had Claimed Refund Of Inr 4,68,29,020 In The Return Of Income.

For Appellant: Sri.Padam Chand Khincha, CAFor Respondent: Sri.Manjunath Karkihalli, CIT-DR

Section 115JSection 143(2)Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 92C

read with section 144C of the I.T.Act incorporating the TP adjustment proposed by the TPO. 4. Aggrieved, the assessee filed objections before the Dispute Resolution Panel (DRP). The DRP granted partial relief to the assessee. Consequent to the DRP’s directions, the TP adjustment of Rs.2 ... with section 144C(13) read with section 144B of the Income Tax Act, 1961 ("the Act") in pursuance of the directions issued by Dispute Resolution Panel ("DRP"), Bangalore dated 26 January 2022 under section 144C(5) of the Act ("impugned order"), inter-alia on the following grounds, which are without

Levi Strauss (India) Private Limited, Bengaluru vs. Income Tax Officer, Ward-4(1)(1), Bangalore

In the result, ground 10(c) is allowed for statistical purposes

ITA 223/BANG/2021[2016-17]Status: DisposedITAT Bangalore13 Sept 2022AY 2016-17

For Appellant: Smt.Shreya Loyalka, CAFor Respondent: Sri.Bijoy Kumar Panda, CIT-DR

Section 143(2)Section 143(3)Section 288ASection 37Section 92C

assessee has also filed additional grounds, which read as follows:- “1. The learned AO / Transfer Pricing Officer ('TPO') and the learned Dispute Resolution Panel (DRP') have erred, in facts, in computing operating margins for comparable companies mentioned as follows; (a) India Tourism Devp. Corpn. Limited. (Segmental

M/S Conduent Business Services India LLP, Bangalore vs. Assistant Commissioner of Income Tax Circle-4(2)(1), Bangalore

In the result, ground No.1 to 3 is allowed for statistical purposes

ITA 3346/BANG/2018[2014-15]Status: DisposedITAT Bangalore13 Sept 2022AY 2014-15

Bench: Shri N.V. Vasudevan & Shri Laxmi Prasad Sahu

For Appellant: Shri Nageswar Rao, AdvocateFor Respondent: Shri Praveen Karanth, CIT (DR)

Section 133(6)Section 143(3)Section 920

credit of INR 3,91.16,490, however credit of only INR 3,90.77.420 was allowed by Ld. AO. While considering these objections, Dispute Resolution Panel (Ld. DRP') on pg 59 of the appeal set refrained from adjudicating on both the abovementioned issues stating that Ld. Panel can adjudicate only variations

Spencer Stuart International B.V., Mumbai vs. The Asstt. CIT (International Taxation)-4(2)(2), Mumbai

In the result, appeals filed by the assessee are allowed

ITA 1148/MUM/2021[2016-17]Status: DisposedITAT Mumbai06 Sept 2022AY 2016-17

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

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

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

Larsen and Toubro Ltd, Mumbai vs. Asst CIT RG 26(2), Mumbai

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

ITA 1464/MUM/2017[2012-13]Status: DisposedITAT Mumbai02 Sept 2022AY 2012-13

Bench: Shri B. R. Baskaran, Am & Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T(Tp).A. No.1464/Mum/2017 (निर्धारण वर्ा / Assessment Years: 2012-13) Larsen & Toubro Ltd. – बिधम/ Acit, Range-26(2) Scomi Engineering Bhd. Mumbai. Vs. Consortium Near Wadala Depot Building, Monorail Station, Pratiksha Nagar, Wadala (E), Mumbai- 400037. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaaal3046N (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Nayan Thakkar Revenue By: Shri Samual Pitta (Dr) सुनवाई की तारीख / Date Of Hearing: 11/08/2022 घोषणा की तारीख /Date Of Pronouncement: 02/09/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Assessing Officer (Hereinafter “Ao”) Dated 14.12.2016 Passed U/S 143(3) Read With Section 144C Of The Income Tax Act, 1961 (Hereinafter “The Act”) Pursuant To The Dispute Resolution Panel-1, Mumbai (Drp) Directions U/S 144C(5) Dated 24.11.2016. 2. At The Outset, It Has Been Brought To Our Notice That Assessee Have Filed An Application For Withdrawal Of Appeal By Letter Dated 18.06.2022 Wherein It Has Pointed Out That It Had Applied For The Vivad Se Vishwaas Act 2020 (Hereinafter “The Scheme”) By Filing Form No- 1 & 2; & Pursuant Thereto The Assessee Received Certificate In Form No- 3 From The Ld. Pcit-17; & The Assessee In Turn Filed Form No- 4 (Expressing Its Intention To Withdraw This Appeal) & Resultantly Had Received Form No- 5 (I.E. Full & Final Settlement Order Dated

For Appellant: Shri Nayan ThakkarFor Respondent: Shri Samual Pitta (DR)

Section 143(3)Section 144CSection 144C(5)

dated 14.12.2016 passed u/s 143(3) read with section 144C of the Income Tax Act, 1961 (hereinafter “the Act”) pursuant to the Dispute Resolution Panel-1, Mumbai (DRP) directions u/s 144C(5) dated 24.11.2016. 2. At the outset, it has been brought to our notice that assessee have filed

Schneider Electric It Business India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Ltu, Circle-2, Bangalore

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

ITA 185/BANG/2022[2017-18]Status: DisposedITAT Bangalore01 Sept 2022AY 2017-18

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.185/Bang/2022 Assessment Year: 2017-18

For Appellant: Shri Rohit Tiwari, A.RFor Respondent: Shri Manjunath Karkihalli, D.R

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

dated 25.2.2022 u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Act consequent to the direction of the Ld. Dispute Resolution Panel (“DRP”) dated 12.1.2022. The assessee has raised following revised grounds of appeal:- IT(TP)A No.185/Bang/2022 Schneider Electric IT Business India Pvt. Ltd., Bangalore Page ... arid liable to be quashed to the extent it confirms the additions/ disallowances made in the assessment, order. 2. That the Learned Dispute Resolution Panel ("Ld. DRP") ignored the judicial pronouncements and erred in dismissing the grounds of objections raised by the Appellant and upholding the adjustment proposed

Dow Agro Sciences India P. Ltd., Mumbai vs. Dy CIT-14 (1)(2), Mumbai

The appeal are disposed of as infructuous

ITA 1234/MUM/2021[2016-17]Status: DisposedITAT Mumbai30 Aug 2022AY 2016-17

Bench: Sixty Days Prior To “The Timeline For The Assessment Order, It Is Implied That Such Order Must Precede 31 December By Not Less Than Sixty Days.”

For Appellant: Sh. Nishant ThakkarFor Respondent: Ms. Samruddhi Dhananjay Hande

Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 92C

Income Tax Act, 1961 (hereinafter referred to as „the Act‟) for the Assessment Year 2016-17, as per directions issued by Dispute Resolution Panel 1, [hereinafter referred to as „the DRP‟] under Section 144C(5) of the Act. 2. When the matter was taken for hearing, the Ld. Authorised Representative