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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

Juniper Networks India Pvt. Ltd., Mumbai vs. DCIT.- CC- 2(4), Mumbai

The appeal is partly allowed

ITA 7412/MUM/2017[2013-14]Status: DisposedITAT Mumbai30 Aug 2022AY 2013-14
For Appellant: Vijay MehtaFor Respondent: Dr. Yogesh Kamat
Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 234ASection 271(1)(c)

Marketing Support services That the learned AO erred on facts and in law in making addition based on the directions of Hon'ble Dispute Resolution Panel (referred to as the 'DRP') to the income of the Appellant to the extent of INR 36,465,110/- on account of alleged difference

Brocade Communications Systems Private Limited, Bengluru vs. Principal Commissioner of Income Tax-1, Bengaluru

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

ITA 656/BANG/2021[2013-14]Status: DisposedITAT Bangalore30 Aug 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2013-14 M/S. Brocade Communications Systems Pvt. Ltd., Floor 3, B & C Wing & The Principal Floor 8, D Wing, S1 Commissioner Of Wipro Electronic City Income Tax – 1, Sez, Doddathogur Bengaluru. Vs. Village, Bengaluru – 560 100. Pan: Aaccb4490N Appellant Respondent : Smt. Tanmayee Rajkumar, Assessee By Advocate : Smt. Priyadarshini Revenue By Baseganni, Addl. Cit (Dr) Date Of Hearing : 28-07-2022 Date Of Pronouncement : 30-08-2022 Order Per Beena Pillaipresent Appeal Is Filed By The Assessee Against Order Dated 18/03/2020 Passed By The Ld.Pr.Cit For A.Y. 2013-14 On Following Grounds Of Appeal: “1. The Order Of The Principal Commissioner Of Income Tax ('Pr.Cit') Passed Under Section 263 Of The Income-Tax Act, 1961 ('The Act'), Is Bad In Law & Liable To Be Quashed. 2. The Learned Pr.Cit Erred In Law & Facts In Concluding That The Order Of The Assessing Officer ('Ao') Is "Erroneous

For Respondent: Smt. Tanmayee Rajkumar
Section 10ASection 143(3)Section 144C(5)Section 263Section 28Section 92C

interests of the revenue. 6. That without prejudice. the final assessment order having been passed pursuant to the directions of the Dispute Resolution Panel, which consists of three officers in the rank of the Commissioner of Income-tax. the order was not amenable for revision under Section

Arm Embedded Technologies Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle- 1(1)(1), Bengaluru

In the result, appeal of the assessee stands partly allowed

ITA 235/BANG/2021[2016-17]Status: DisposedITAT Bangalore30 Aug 2022AY 2016-17
For Appellant: 2.1 Rejecting the value of international transaction of provision of SWD and proFor Respondent: Shri T. Suryanarayana
Section 133(6)Section 143(3)Section 144C(13)Section 92D

with section 144C(13) of the Act, pursuant to Page 2 of 51 IT(TP)A No. 235/Bang/2021 the directions of the learned Dispute Resolution Panel ('learned Panel') to the extent prejudicial to the Appellant, is bad in law and liable to be quashed. 2. That on the facts

Wellis Processing Services India P.Ltd, Mumbai vs. DCIT RG 2(3)(1), Mumbai

In the result, the appeal filed by the assessee in respect of T

ITA 691/MUM/2016[2007-08]Status: DisposedITAT Mumbai29 Aug 2022AY 2007-08

Bench: Hon’Ble High Court Of Bombay.

Section 143(3)

Assessing officer for assessment year 2007-08 u/s 143(3) r.w.s. 144C(13) of the Act in pursuance of directions issued by Ld Dispute Resolution Panel (DRP). 2. The assessee herein is earlier known as “Willis Processing Service (India) Private Limited”. It is an Export Oriented Unit (EOU) under Software

DCIT Cent. Cir. 5(2), Mumbai vs. Ipca Laboratories Ltd., Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 5227/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

addition of `29,62,754/- u/s.92CA(4) of the Act on account of adjustment in Arms Length Price (ALP) pursuant to directions of Dispute Resolution Panel (DRP) u's.144C(5) of the Act, dated 05.08.2010 and the order of Joint Commissioner of Income-tax, Transfer pricing 1(1), Mumbai ... that extent deduction is reduced. The total income was computed at ₹ 20,17,31,742/-. The assessee preferred he objection before the learned Dispute Resolution Panel no.2 which gave the direction on 5th August, 2010. It upheld the addition on sale of products to its associated enterprises. Therefore, adjustment proposed

Ipca Laboratories Ltd, Mumbai vs. DCIT Ltu, Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3811/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

addition of `29,62,754/- u/s.92CA(4) of the Act on account of adjustment in Arms Length Price (ALP) pursuant to directions of Dispute Resolution Panel (DRP) u's.144C(5) of the Act, dated 05.08.2010 and the order of Joint Commissioner of Income-tax, Transfer pricing 1(1), Mumbai ... that extent deduction is reduced. The total income was computed at ₹ 20,17,31,742/-. The assessee preferred he objection before the learned Dispute Resolution Panel no.2 which gave the direction on 5th August, 2010. It upheld the addition on sale of products to its associated enterprises. Therefore, adjustment proposed

Asst CIT (Ltu) 1, Mumbai vs. Ipca Laboratories Ltd, Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3691/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

addition of `29,62,754/- u/s.92CA(4) of the Act on account of adjustment in Arms Length Price (ALP) pursuant to directions of Dispute Resolution Panel (DRP) u's.144C(5) of the Act, dated 05.08.2010 and the order of Joint Commissioner of Income-tax, Transfer pricing 1(1), Mumbai ... that extent deduction is reduced. The total income was computed at ₹ 20,17,31,742/-. The assessee preferred he objection before the learned Dispute Resolution Panel no.2 which gave the direction on 5th August, 2010. It upheld the addition on sale of products to its associated enterprises. Therefore, adjustment proposed

Ipca Laboratories Ltd, Mumbai vs. Asst CIT (Ltu), Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3597/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

addition of `29,62,754/- u/s.92CA(4) of the Act on account of adjustment in Arms Length Price (ALP) pursuant to directions of Dispute Resolution Panel (DRP) u's.144C(5) of the Act, dated 05.08.2010 and the order of Joint Commissioner of Income-tax, Transfer pricing 1(1), Mumbai ... that extent deduction is reduced. The total income was computed at ₹ 20,17,31,742/-. The assessee preferred he objection before the learned Dispute Resolution Panel no.2 which gave the direction on 5th August, 2010. It upheld the addition on sale of products to its associated enterprises. Therefore, adjustment proposed

DCIT (Ltu) 1, Mumbai vs. Ipca Laboratories Ltd, Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2815/MUM/2015[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

addition of `29,62,754/- u/s.92CA(4) of the Act on account of adjustment in Arms Length Price (ALP) pursuant to directions of Dispute Resolution Panel (DRP) u's.144C(5) of the Act, dated 05.08.2010 and the order of Joint Commissioner of Income-tax, Transfer pricing 1(1), Mumbai ... that extent deduction is reduced. The total income was computed at ₹ 20,17,31,742/-. The assessee preferred he objection before the learned Dispute Resolution Panel no.2 which gave the direction on 5th August, 2010. It upheld the addition on sale of products to its associated enterprises. Therefore, adjustment proposed

Ipca Laboratories Ltd, Mumbai vs. Asst CIT (Ltu), Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2493/MUM/2015[2008-09]Status: DisposedITAT Mumbai29 Aug 2022AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

addition of `29,62,754/- u/s.92CA(4) of the Act on account of adjustment in Arms Length Price (ALP) pursuant to directions of Dispute Resolution Panel (DRP) u's.144C(5) of the Act, dated 05.08.2010 and the order of Joint Commissioner of Income-tax, Transfer pricing 1(1), Mumbai ... that extent deduction is reduced. The total income was computed at ₹ 20,17,31,742/-. The assessee preferred he objection before the learned Dispute Resolution Panel no.2 which gave the direction on 5th August, 2010. It upheld the addition on sale of products to its associated enterprises. Therefore, adjustment proposed

Ipca Laboratories Ltd, Mumbai vs. DCIT (Ltu), Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3267/MUM/2012[2007-08]Status: DisposedITAT Mumbai29 Aug 2022AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

addition of `29,62,754/- u/s.92CA(4) of the Act on account of adjustment in Arms Length Price (ALP) pursuant to directions of Dispute Resolution Panel (DRP) u's.144C(5) of the Act, dated 05.08.2010 and the order of Joint Commissioner of Income-tax, Transfer pricing 1(1), Mumbai ... that extent deduction is reduced. The total income was computed at ₹ 20,17,31,742/-. The assessee preferred he objection before the learned Dispute Resolution Panel no.2 which gave the direction on 5th August, 2010. It upheld the addition on sale of products to its associated enterprises. Therefore, adjustment proposed

Ipca Laboratories Ltd, Mumbai vs. ACIT (Ltu), Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8120/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

addition of `29,62,754/- u/s.92CA(4) of the Act on account of adjustment in Arms Length Price (ALP) pursuant to directions of Dispute Resolution Panel (DRP) u's.144C(5) of the Act, dated 05.08.2010 and the order of Joint Commissioner of Income-tax, Transfer pricing 1(1), Mumbai ... that extent deduction is reduced. The total income was computed at ₹ 20,17,31,742/-. The assessee preferred he objection before the learned Dispute Resolution Panel no.2 which gave the direction on 5th August, 2010. It upheld the addition on sale of products to its associated enterprises. Therefore, adjustment proposed

Ipca Laboratories Ltd, Mumbai vs. DCIT (Ltu), Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8084/MUM/2010[2006-07]Status: DisposedITAT Mumbai29 Aug 2022AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

addition of `29,62,754/- u/s.92CA(4) of the Act on account of adjustment in Arms Length Price (ALP) pursuant to directions of Dispute Resolution Panel (DRP) u's.144C(5) of the Act, dated 05.08.2010 and the order of Joint Commissioner of Income-tax, Transfer pricing 1(1), Mumbai ... that extent deduction is reduced. The total income was computed at ₹ 20,17,31,742/-. The assessee preferred he objection before the learned Dispute Resolution Panel no.2 which gave the direction on 5th August, 2010. It upheld the addition on sale of products to its associated enterprises. Therefore, adjustment proposed

ACIT Cen Cir 13, Mumbai vs. Ipca Laboratories Ltd, Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 7511/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

addition of `29,62,754/- u/s.92CA(4) of the Act on account of adjustment in Arms Length Price (ALP) pursuant to directions of Dispute Resolution Panel (DRP) u's.144C(5) of the Act, dated 05.08.2010 and the order of Joint Commissioner of Income-tax, Transfer pricing 1(1), Mumbai ... that extent deduction is reduced. The total income was computed at ₹ 20,17,31,742/-. The assessee preferred he objection before the learned Dispute Resolution Panel no.2 which gave the direction on 5th August, 2010. It upheld the addition on sale of products to its associated enterprises. Therefore, adjustment proposed

Textron India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result, the appeal filed by the assessee stands allowed on the grounds argued by assessee and other issues that has not been pressed is kept open

ITA 711/BANG/2017[2012-13]Status: DisposedITAT Bangalore26 Aug 2022AY 2012-13
For Appellant: Shri Sumit Khurana, CAFor Respondent: Shri V.S. Chakrapani, CIT-DR
Section 92C(3)(c)Section 92D

appeal: “The grounds mentioned herein are without prejudice to one another. 1. That the Assessing Officer in pursuance of the directions of the Dispute Resolution Panel erred in law and on facts in rejecting the Transfer Pricing documentation maintained by the Appellant under Section 92D of the Income ... accordingly proceeded to determine the arm's length price. 2. That the Assessing Officer/Transfer Pricing Officer in pursuance of the directions of the Dispute Resolution Panel erred in law and on facts in disregarding the application of multiple-year/ prior-year data as used by the Appellant in the Transfer

DCIT, Cir-6(2)(2), Mumbai vs. Diageo India Pvt.Ltd., Mumbai

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

ITA 2858/MUM/2016[2011-12]Status: DisposedITAT Mumbai25 Aug 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Diageo India P. Ltd. Dcit 4Th Floor, Nicholas Piramal Tower Rg 6(2)(2) Peninsula Corporate Park, Aayakar Bhavan, Vs. Ganpatrao Kadam Marg, Mk Road, Lower Parel, Mumbai-400 020 Mumbai-400 013 (Appellant) (Respondent) Pan No. Aaaci 3378 L Diageo India P. Ltd. Dcit 4Th Floor, Nicholas Piramal Tower Rg 6(2)(2) Peninsula Corporate Park, Aayakar Bhavan, Vs. Ganpatrao Kadam Marg, Mk Road, Lower Parel, Mumbai-400 020 Mumbai-400 013 (Appellant) (Respondent)

For Appellant: Shri Nishant Thakkar &For Respondent: Ms. Vatsalaa Jha, CIT DR
Section 143(3)Section 144C(13)Section 253Section 92BSection 92C

Commissioner of Income Tax, Circle 6(2)(2), Mumbai (The learned AO) in pursuance of direction issued by the learned Dispute Resolution Panel-1 dated 31st December, 2015 raising following grounds of appeal:- “Based on the facts and circumstances of the case, Diageo India Private Limited (hereinafter referred ... section 143(3) read with section 144C(13) of the Income-tax Act, 1961 (the Act) in pursuance of the directions issued by Dispute Resolution Panel-1 (DRP), Mumbai dated 31 December 2015 under section 253 of the Act on the following grounds: On the facts and in the circumstances

Diageo India P.Ltd, Mumbai vs. DCIT RG 6(2)(2), Mumbai

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

ITA 1002/MUM/2016[2011-12]Status: DisposedITAT Mumbai25 Aug 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Diageo India P. Ltd. Dcit 4Th Floor, Nicholas Piramal Tower Rg 6(2)(2) Peninsula Corporate Park, Aayakar Bhavan, Vs. Ganpatrao Kadam Marg, Mk Road, Lower Parel, Mumbai-400 020 Mumbai-400 013 (Appellant) (Respondent) Pan No. Aaaci 3378 L Diageo India P. Ltd. Dcit 4Th Floor, Nicholas Piramal Tower Rg 6(2)(2) Peninsula Corporate Park, Aayakar Bhavan, Vs. Ganpatrao Kadam Marg, Mk Road, Lower Parel, Mumbai-400 020 Mumbai-400 013 (Appellant) (Respondent)

For Appellant: Shri Nishant Thakkar &For Respondent: Ms. Vatsalaa Jha, CIT DR
Section 143(3)Section 144C(13)Section 253Section 92BSection 92C

Commissioner of Income Tax, Circle 6(2)(2), Mumbai (The learned AO) in pursuance of direction issued by the learned Dispute Resolution Panel-1 dated 31st December, 2015 raising following grounds of appeal:- “Based on the facts and circumstances of the case, Diageo India Private Limited (hereinafter referred ... section 143(3) read with section 144C(13) of the Income-tax Act, 1961 (the Act) in pursuance of the directions issued by Dispute Resolution Panel-1 (DRP), Mumbai dated 31 December 2015 under section 253 of the Act on the following grounds: On the facts and in the circumstances

M/S Infineon Technologies India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore

ITA 3355/BANG/2018[2014-15]Status: DisposedITAT Bangalore25 Aug 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 3355/Bang/2018 Assessment Year : 2014-15 M/S. Infineon Technologies India Pvt. The Deputy Ltd., Commissioner Of 9Th Floor, Prestige Income Tax, Thirulakshmi, Circle – 3(1)(1), No. 11, Mg Road, Vs. Bangalore. Bangalore. Pan: Aabcs6967N Appellant Respondent : Shri K.R. Vasudevan, Assessee By Advocate : Shri Sumer Singh Meena, Revenue By Cit Dr Date Of Hearing : 12-07-2022 Date Of Pronouncement : 25-08-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Assessment Order Dated 26/10/2018 By The Ld.Dcit, Circle – 3(1)(1), Bangalore On Following Grounds Of Appeal: “A. Transfer Pricing The Grounds Mentioned Hereinafter Are Without Prejudice To One Another. 1. The Learned Assessing Officer ('Learned Ao'), Learned Transfer Pricing Officer ('Learned Tpo') & The Honourable Dispute Resolution Panel ('Hon'Ble Drp') Grossly Erred In Adjusting The Transfer Price By Inr 9,56,93,721/- With Respect To The International

For Respondent: Shri K.R. Vasudevan
Section 92C

hereinafter are without prejudice to one another. 1. The learned Assessing Officer ('learned AO'), learned Transfer Pricing Officer ('learned TPO') and the Honourable Dispute Resolution Panel ('Hon'ble DRP') grossly erred in adjusting the transfer price by INR 9,56,93,721/- with respect to the international Page

M/S Praxair India Pvt Ltd, Bangalore vs. Deputy Commissioner of Income Tax Ltpu Circle-1, Bangalore

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

ITA 2839/BANG/2017[2013-14]Status: DisposedITAT Bangalore25 Aug 2022AY 2013-14
For Appellant: Sri.T.Suryanarayana, Senior AdvocateFor Respondent: Sri.Bijoy Kumar Panda, CIT-DR
Section 143(2)Section 143(3)Section 14ASection 37

incorporating the aforesaid TP adjustments and making certain additions / disallowances on corporate tax front. 4. Aggrieved, the assessee filed objections before the Dispute Resolution Panel (DRP). The DRP vide its directions dated 18.09.2017, largely confirmed the draft assessment order. Pursuant to the DRP’s directions, the final assessment order

Oocl Logistics (India) P.Ltd, Mumbai vs. ITO 7(3)(1), Mumbai

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

ITA 2001/MUM/2015[2010-11]Status: DisposedITAT Mumbai24 Aug 2022AY 2010-11

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Siddhesh ChauguleFor Respondent: Ms. Vatsalaa Jha
Section 143(3)Section 144C(13)Section 234BSection 244A

case and in law, the learned Transfer Pricing Officer (TPO) the loaned Assessing Officer (AO) under directions issued by the Hon'ble Dispute Resolution Panel (DRP) in making an addition of Rs. 2,93,56,738/- to the Appellant's total income under the provisions of Chapter ... passed order under section 143(3) read with section 144C of the Act. The assessee filed detailed objections before the learned Dispute Resolution Panel (‘learned DRP’) against the adjustment proposed by the TPO/AO. The learned DRP vide directions dated 26/12/2014, issued under section 144C(5) of the Act dismissed