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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

Van Oord Dredging and Marine Contractors Bv, Mumbai vs. DCIT (It) 4(3)(1), Mumbai

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

ITA 1382/MUM/2017[2012-13]Status: DisposedITAT Mumbai15 Jul 2022AY 2012-13

Bench: Shri Amit Shukla & Shri Amarjit Singhvan Oord Dredging & Vs. Deputy Commissioner Of Marine Contractors Bv Income-Tax (International 201, 2Nd Floor, Central Taxation)-4(3)(1) Plaza, 166 Cst Road, 16Th Floor, Air India Kalina, Building, Nariman Point, Mumbai - 400098 Mumbai - 400020 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Aaach3500M Appellant .. Respondent

For Appellant: Nishant Thakkar &For Respondent: K.C. Kanojiya
Section 144C(13)Section 92CSection 92C(3)

Amarjit Singh (AM): The present appeal filed by the assessee is directed against the order passed by the Dispute Resolution Panel (DRP)-2, Mumbai, which in turn arises from the order passed by the A.O u/s 144C(13) r.w.s 143(3) of the Act for A.Y.2012-13. The assessee has raised

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

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

ITA 250/BANG/2022[2017-18]Status: DisposedITAT Bangalore15 Jul 2022AY 2017-18

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.250/Bang/2022 : Asst.Year 2017-2018 & Sa No.22/Bang/2022 M/S.Sprinklr India Private Limited The Deputy Commissioner Of 3Rd Floor, East Wing Building Income-Tax, Circle 6(1)(2) V. Bengaluru. No.3, Block B, Divyashree 770 Town Centre, Off Hal Airport Road, Yamlur P.O. Bengaluru – 560 037. Pan : Aaqcs9370N. (Appellant/Applicant) (Respondent) Appellant By : Sri.Tata Krishna, Advocate Respondent By : Sri.Sumeer Singh Meena, Cit-Dr Date Of Pronouncement : 15.07.2022 Date Of Hearing : 13.07.2022 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 18.02.2022. The Relevant Assessment Year Is 2017-2018. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Wholly Owned Subsidiary Of Sprinklr Us. It Provides Software Development Services To Its Parent Company. For The Assessment Year 2017-2018, The Return Of Income Was Filed On 31.10.2017 Declaring Total Income Of Rs.24,99,66,540. The Assessment Was Selected For Scrutiny & Notice U/S 143(2) Of The I.T.Act Was Issued. During The 2 It(Tp)A No.250/Bang/2022 & Sa 22/B/2022. M/S.Sprinklr India Private Limited. Course Of Assessment Proceedings, The Matter Was Referred To The Transfer Pricing Officer (Tpo) To Determine The Arm’S Length Price (Alp) Of The International Transaction Undertaken By The Assessee With Its Associated Enterprises (Aes). The Tpo Vide His Order U/S 92Ca Of The I.T.Act Dated 27.01.2021 Determined The Tp Adjustment Of Rs.12,63,71,153. The Details Of The Tp Adjustment Made By The Tpo Reads As Follows:-

For Appellant: Sri.Tata Krishna, AdvocateFor Respondent: Sri.Sumeer Singh Meena, CIT-DR
Section 143(2)Section 92C

incorporating the TP adjustment proposed by the TPO. 4. Aggrieved by the draft assessment order, the assessee filed objections before the Dispute Resolution Panel (DRP) on 28.05.2021. The DRP vide order dated 24.01.2022 rejected the objections raised by the assessee. However, the DRP in its order directed

Mutha Engineering Pvt. Ltd., Mumbai vs. The Dy. Commissioner of Income Tax Circle 4 (2)(2), Mumbai

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

ITA 7226/MUM/2018[2014-15]Status: DisposedITAT Mumbai13 Jul 2022AY 2014-15

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri G.P. MehtaFor Respondent: Shri Tejinder Pal Singh Anand
Section 143(3)Section 144C(5)Section 40ASection 92B

section 144C(5) of the Income Tax Act, 1961 (‘the Act’) pursuant to the directions dated 26/09/2018, issued by the Dispute Resolution Panel (DRP)–3, Mumbai, for the assessment year 2014–15. Mutha Engineering Pvt. Ltd. ITA No.7226/Mum./2018 2. In the present appeal, the assessee is aggrieved against

M/S Marlabs Innovations Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-4(1)(2), Bangalore

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

ITA 457/BANG/2019[2011-12]Status: DisposedITAT Bangalore13 Jul 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2011-12 M/S. Marlabs Innovations Pvt. Ltd., (Successor Of Marlabs Software Pvt. Ltd.), The Deputy 14Th Floor, Citrine Block-4, Commissioner Of Bagmane World Technology Income Tax, Centre, Circle – 4(1)(2), Marathalli Outer Ring Vs. Bangalore. Road, Mahadevapura, Bengaluru – 560 048. Pan: Aaccm6627Q Appellant Respondent Assessee By : Shri L. Bharath, Ca Revenue By : Shri Arun Kumar, Cit Dr Date Of Hearing : 23-06-2022 Date Of Pronouncement : 13-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 28/12/2018 Passed By Ld.Dcit, Circle – 4(1)(2), Bangalore For A.Y. 2011-12. 2. The Assessee Has Raised Various Issues On The Transfer Pricing Adjustment Made In Respect Of The International Transactions Between Assessee & Its Ae.

For Appellant: Shri L. Bharath, CAFor Respondent: Shri Arun Kumar, CIT DR
Section 142(1)Section 143(2)Section 2(31)Section 394

name of SPIL.  On April 12, 2016, the Assessee filed objections against the proposed additions in the draft assessment order before the Dispute Resolution Panel (DRP). The objections were filed by MSIL as successor in interest of erstwhile SPIL.  On October 14, 2016, DRP gave its directions

Sigma Aldrich Chemicals Private Limited, Bangalore vs. DCIT, Bangalore

In the result, grounds 22 to 22

ITA 596/BANG/2016[2011-12]Status: DisposedITAT Bangalore11 Jul 2022AY 2011-12

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.418/Bang/2015 : Asst.Year 2010-2011 It(Tp)A No.596/Bang/2016 : Asst.Year 2011-2012 M/S.Sigma Aldrich Chemicals The Deputy Commissioner Of Private Limited, No.12, Income-Tax, Circle 6(1)(1) V. Bangalore. Bommasandra-Jagani Link Road, Bommasandra Industrial Area Bangalore – 560 100. Pan : Aahcs1882L. (Appellant) (Respondent) Appellant By : Sri.Tata Krishna, Advocate Respondent By : Sri.Sumer Singh Meena, Cit-Dr Date Of Pronouncement : 11.07.2022 Date Of Hearing : 07.07.2022 O R D E R Per George George K, Jm : These Appeals At The Instance Of The Assessee Are Directed Against Two Final Assessment Order Dated 19.01.2015 & 28.01.2016 For Assessment Years 2010-2011 & 2011- 2012, Respectively. Common Issues Are Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Sri.Tata Krishna, AdvocateFor Respondent: Sri.Sumer Singh Meena, CIT-DR
Section 153Section 153BSection 92C

option either to file his acceptance of the variation of the assessment or file his objection to any such variation with the Dispute Resolution Panel and also the Assessing Officer. Sub-Section (5) of 14 IT(TP)A No.418/B/2015 & 596/B/2016. M/s.Sigma Aldrich Chemicals Private Limited. Section 144C ... provides that if any objections are raised by the assessee before the Dispute Resolution Panel, the Panel is empowered to issue such direction as it thinks fit for the guidance of the Assessing Officer after considering various details provided in Clauses (A) to (G) thereof. Sub- Section (l3) of Section

Sigma Aldrich Chemicals Private Limited, Bangalore vs. DCIT, Bangalore

In the result, grounds 22 to 22

ITA 418/BANG/2015[2010-11]Status: DisposedITAT Bangalore11 Jul 2022AY 2010-11

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.418/Bang/2015 : Asst.Year 2010-2011 It(Tp)A No.596/Bang/2016 : Asst.Year 2011-2012 M/S.Sigma Aldrich Chemicals The Deputy Commissioner Of Private Limited, No.12, Income-Tax, Circle 6(1)(1) V. Bangalore. Bommasandra-Jagani Link Road, Bommasandra Industrial Area Bangalore – 560 100. Pan : Aahcs1882L. (Appellant) (Respondent) Appellant By : Sri.Tata Krishna, Advocate Respondent By : Sri.Sumer Singh Meena, Cit-Dr Date Of Pronouncement : 11.07.2022 Date Of Hearing : 07.07.2022 O R D E R Per George George K, Jm : These Appeals At The Instance Of The Assessee Are Directed Against Two Final Assessment Order Dated 19.01.2015 & 28.01.2016 For Assessment Years 2010-2011 & 2011- 2012, Respectively. Common Issues Are Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Sri.Tata Krishna, AdvocateFor Respondent: Sri.Sumer Singh Meena, CIT-DR
Section 153Section 153BSection 92C

option either to file his acceptance of the variation of the assessment or file his objection to any such variation with the Dispute Resolution Panel and also the Assessing Officer. Sub-Section (5) of 14 IT(TP)A No.418/B/2015 & 596/B/2016. M/s.Sigma Aldrich Chemicals Private Limited. Section 144C ... provides that if any objections are raised by the assessee before the Dispute Resolution Panel, the Panel is empowered to issue such direction as it thinks fit for the guidance of the Assessing Officer after considering various details provided in Clauses (A) to (G) thereof. Sub- Section (l3) of Section

Accenture Solutions Pvt Ltd. (Asol) As A Successor to Accenture Serivces Pvt Ltd (Aspl), Mumbai vs. Dy CIT Circle- 14 (1)(1), Mumbai

ITA 8008/MUM/2019[2015-16]Status: DisposedITAT Mumbai07 Jul 2022AY 2015-16

Bench: Shri Baskaran Br & Shri Kuldip Singhassessment Year: 2015-16 M/S. Accenture Solutions The Dy. Commissioner O Pvt. Ltd. (‘Asol’), Income Tax, (As A Successor To Circle 14(1)(1), Accenture Services Pvt. 475, Aayakar Bhavan, Ltd. (‘Aspl’) Which Has M.K. Road, Merged Into Asol With An Mumbai - 400020 Effective Date Of 1 Vs. December 2016) Plant 3, Godrej & Boyce Complex, Phirojshah Nagar, Vikhroli West, Off L.B.S Marg, Mumbai – 400 079 Pan: Aacca8997K (Appellant) (Respondent)

For Appellant: Shri Percy J. Pardiwalla, A.RFor Respondent: Dr. Yogesh Kamat, D.R
Section 143Section 143(3)Section 144C(13)Section 92CSection 92C(3)

sought to set aside the impugned order dated 12.09.2019 passed by the Assessing Officer (AO) in consonance with the orders passed by the Disputes Resolution Panel (DRP)/Transfer Pricing Officer (TPO) under section 143 (3) read with section 144C(13) of the Income-tax Act, 1961 (for short ... under Section 143(3) r.w.s 144C( 13) of the Income- tax Act, 1961 ('Act') ('Assessment order'), in pursuance to the Directions issued by Dispute Resolution Panel - 1(WZ) ('Hon'ble DRP'), Mumbai, on the following grounds: On the facts and circumstances of the case and in law, the learned

Owens Corning (Singapore) Pte.Ltd ., Mumbai vs. The Dy CIT(International Tax)Circle-3(2)(2), Mumbai

In the result, the ITA No

ITA 742/MUM/2021[2017-18]Status: DisposedITAT Mumbai06 Jul 2022AY 2017-18

Bench: Us Is A Company Incorporated In & Fiscally Domiciled In, The Republic Of Singapore. During The Relevant Previous Year, The Assessee Company Provided Bushing & Fabrication Services To Its

Section 143(3)

assessee on 1st February 2016. 4. In the first ground of appeal, the assessee is aggrieved that “the Assessing Officer/ the Dispute Resolution Panel has erred in taxing the amount of Rs 4,84,44,048 received by the appellant during the year under consideration as fabrication charges as „fees ... with ROI) 6. When the stand so taken by the Assessing Officer was put to the assessee, the assessee raised grievances before the Dispute Resolution Panel, but without any success. Learned DRP confirmed the action of the Assessing Officer, on the basis of the following reasoning: We have gone through

Owens Corning (Singapore) Pte. Ltd., Mumbai vs. Dy. CIT (It) Circle-3 (2)(2), Mumbai

In the result, the ITA No

ITA 5731/MUM/2019[2016-17]Status: DisposedITAT Mumbai06 Jul 2022AY 2016-17

Bench: Us Is A Company Incorporated In & Fiscally Domiciled In, The Republic Of Singapore. During The Relevant Previous Year, The Assessee Company Provided Bushing & Fabrication Services To Its

Section 143(3)

assessee on 1st February 2016. 4. In the first ground of appeal, the assessee is aggrieved that “the Assessing Officer/ the Dispute Resolution Panel has erred in taxing the amount of Rs 4,84,44,048 received by the appellant during the year under consideration as fabrication charges as „fees ... with ROI) 6. When the stand so taken by the Assessing Officer was put to the assessee, the assessee raised grievances before the Dispute Resolution Panel, but without any success. Learned DRP confirmed the action of the Assessing Officer, on the basis of the following reasoning: We have gone through

Owens-Corning(Singapore)Pte.Ltd., Mumbai vs. The Deputy Commissioner of Income-Tax (Internatioal Taxation) Circle-3(2)(2), Mumbai

In the result, the ITA No

ITA 2049/MUM/2016[2012-13]Status: DisposedITAT Mumbai06 Jul 2022AY 2012-13

Bench: Us Is A Company Incorporated In & Fiscally Domiciled In, The Republic Of Singapore. During The Relevant Previous Year, The Assessee Company Provided Bushing & Fabrication Services To Its

Section 143(3)

assessee on 1st February 2016. 4. In the first ground of appeal, the assessee is aggrieved that “the Assessing Officer/ the Dispute Resolution Panel has erred in taxing the amount of Rs 4,84,44,048 received by the appellant during the year under consideration as fabrication charges as „fees ... with ROI) 6. When the stand so taken by the Assessing Officer was put to the assessee, the assessee raised grievances before the Dispute Resolution Panel, but without any success. Learned DRP confirmed the action of the Assessing Officer, on the basis of the following reasoning: We have gone through

Dwarikesh Sugar Industries Ltd, Mumbai vs. Assessing Officer, NFAC, Mumbai

ITA 562/MUM/2022[2017-18]Status: DisposedITAT Mumbai05 Jul 2022AY 2017-18

Bench: Shri Baskaran Br & Shri Kuldip Singhassessment Year: 2017-18 M/S. Dwarikesh Sugar The Assessing Officer, Industries Ltd., National Faceless 511, Maker Chamber – V, Vs. Assessment Centre, 211, Nariman Point, Delhi Mumbai – 400 021 Pan: Aabcd 8192N (Appellant) (Respondent)

For Appellant: Shri Jayesh Dadia, A.RFor Respondent: Shri Sambit Mishra, D.R
Section 143Section 143(3)Section 144BSection 144CSection 234Section 253Section 270A

DSIL) (hereinafter referred to as ‘the assessee’) by filing the present appeal, sought to set aside the impugned order dated 28.01.2022 passed by Dispute Resolution Panel [hereinafter referred to as the DRP] qua the assessment year 2017-18 on the grounds inter alia that :- “Dwarikesh Sugar Industries Ltd., the Appellant ... hereinafter referred to as "the 2 M/s. Dwarikesh Sugar Industries Ltd. Act") in pursuance to the directions issued by the Hon'ble Dispute Resolution Panel - 1, Mumbai - 2 (hereinafter referred to as "the Hon'ble DRP") dated 28th January, 2022 under section 144C (5) of the Act on the following

Owens Corning Inc., Mumbai vs. The Dy CIT(International Tax)Circle-3(2)(2), Mumbai

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

ITA 741/MUM/2021[2017-18]Status: DisposedITAT Mumbai04 Jul 2022AY 2017-18

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Sandeep Bhalla a/wFor Respondent: Shri Milind Chavan, Sr. DR
Section 143(3)Section 144Section 234BSection 9(1)Section 9(1)(vii)

raised following grounds:– Owens Corning Inc. ITA No.741/Mum./2021 Re.: Treating lease rentals received as 'Royalty': 1. The Assessing Officer (AO') I Dispute Resolution Panel ('DRP') has erred in taxing the lease rentals received by the appellant of Rs. 2,86,00,164 during the year under consideration by treating ... well as Article 12(4) of the DTAA. 5. The assessee filed detailed objections before the learned Dispute Resolution Panel (“learned DRP”). Vide directions dated 24/02/2021 issued under section 144C(5) of the Act, learned DRP, following its directions in the case of assessee for assessment year 2012–13, rejected

Michael Page International Pte Ltd., Mumbai vs. Dy CIT (Intl. Taxn.)-3(2)(2), Mumbai

In the result, the appeal is allowed in the terms indicated above

ITA 144/MUM/2021[2017-18]Status: DisposedITAT Mumbai04 Jul 2022AY 2017-18
Section 143(3)Section 270ASection 9(1)

case and in law, the Learned Deputy Commissioner of Income-tax (International Taxation) 3(2)(2), Mumbai ('the Learned AO') and the Dispute Resolution Panel (the DRP') erred in holding the amount for business support services of INR 2,99,65,730 and referral fees ... When the stand of the assessee, as noted above, was stated in the draft assessment order, the assessee raised grievances before the Dispute Resolution Panel, but without any success. The Dispute Resolution Panel confirmed the action of the Assessing Officer, and declined to interfere in the matter. Learned Dispute Resolution

Ntt Asia Pacific Holdings Pte. Ltd., Mumbai vs. The Asstt. CIT (International Taxation)-2(1)(2), Mumbai

In the result, the appeal is allowed in the terms indicated above

ITA 1212/MUM/2021[AADC4348L]Status: DisposedITAT Mumbai04 Jul 2022
Section 143(3)

When the stand of the assessee, as noted above, was stated in the draft assessment order, the assessee raised grievances before the Dispute Resolution Panel, but without any success. The Dispute Resolution Panel confirmed the action of the Assessing Officer, and declined to interfere in the matter. Learned Dispute Resolution

Anl Singapore Pte Ltd., Mumbai vs. Dy CIT (International Taxationa)-1(1)(2), Mumbai

In the result, the appeal is allowed in the terms indicated above

ITA 1014/MUM/2021[2017-18]Status: DisposedITAT Mumbai04 Jul 2022AY 2017-18

Bench: Us Is A Company Incorporated In & Fiscally Domiciled In, The Republic Of Singapore & Is Engaged In The Shipping Business. The Assessee Had Earnd An Inland Haulage Charges Of Rs 13,32,16,141 Which Was Not Offered To Tax. When, During The Course Of The Assessment Proceedings, It Was Put To The Assessee As To Why The Said Income Not Be Brought To Tax In The Hands Of The Assessee, It Was, Inter Alia, Submitted By The Assessee As Follows: Assessment Year: 2017-18 Page 2 Of 5

Section 143(3)

taxable in India as per section 44B. Assessment year: 2017-18 Page 4 of 5 5. Aggrieved, assessee raised the objections before the Dispute Resolution Panel but without any success. Even as the DRP did not dispute the fact that the issue is covered by the decision of the coordinate

M Pallonji Shipping P. Ltd, Mumbai vs. DCIT 5(2)(2), Mumbai

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

ITA 5875/MUM/2017[2013-14]Status: DisposedITAT Mumbai30 Jun 2022AY 2013-14

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadalem.Pallonji Shipping Pvt Vs. Dcit – 5(2)(2) Ltd.46A Veetrag Mumbai Chambers, Cawasji Patel Street, Fort, Mumbai-400001 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaecm4615L Appellant .. Respondent Appellant By : Dr.K. Shivaram & Shri Rahul Hakani.Ar Respondent By : Ms.Vatslaaa Jha.Cit.Dr Date Of Hearing 08.06.2022 Date Of Pronouncement 28.06.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm:

For Appellant: Dr.K. Shivaram, &For Respondent: Ms.Vatslaaa Jha.CIT.DR
Section 143(2)Section 143(3)Section 92C

against the order of the A.O passed u/s 143(3) r.w.s 144C(13) of the Act, 1961 in pursuance to directions of the Dispute Resolution Panel (DRP) u/sec 144C(5) of the Act. The assessee has filed the fallowing grounds of appeal as under: M. Pallonji Shipping Pvt Ltd., Mumbai ... facts and in the circumstances of the case and in law, the Hon'ble Dispute Resolution Panel (DRP) erred in upholding the proposed transfer pricing addition of notional interest of Rs. 4,44,67,107/- (net) on account of loan given to M Pallonji Shipping Singapore Pte Ltd (MPS Singapore

Sandisk India Device Design Centre Private Limited, Bengaluru vs. Joint Commissioner of Income Tax, Special Range-6, Bangalore

In the result, the appeal filed by the assessee stands partly allowed as indicated hereinabove

ITA 288/BANG/2021[2016-17]Status: DisposedITAT Bangalore30 Jun 2022AY 2016-17

Bench: Smt. Beena Pillai & Shri. Laxmi Prasad Sahuit(Tp)A No. 288/Bang/2021 Assessment Year : 2016-17 M/S. Sandisk India Device Design Centre Pvt. Ltd., Survey No. 143/1, Amani Bellandur Khane Village, The Joint Prestige Excelsior, Commissioner Of Prestige Tech Park, Income-Tax Marathalli – Sarjapur Outer (Osd), Ring Road, Circle 6 (1)(1), Vs. Kadubeesanahalli, Bangalore. Varthur Hobli, Bangalore – 560 103. Pan: Aaics9204M Appellant Respondent Assessee By : Shri Ajay Roti, Ca : Dr. Manjunath Karkihalli, Revenue By Cit Dr Date Of Hearing : 25-05-2022 Date Of Pronouncement : 30-06-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Final Assessment Order Passed By National E-Assessment Centre, New Delhi On 30.04.2021 For A.Y. 2016-17 On Following Grounds Of Appeal: “The Grounds Stated Hereunder Are Independent Of & Without Prejudice To One Another. The Appellant Submits As Under:

For Appellant: Shri Ajay Roti, CA
Section 92C(3)Section 92D

Additional Commissioner of Income-tax, Transfer Pricing — 2(2) ['the Learned Transfer Pricing Officer' or 'the Ld. TPO']. 1.2. The Hon'ble Dispute Resolution Panel ('Hon'ble Panel') Hon'ble Panel erred in upholding the order of the NeAC , which is bad on facts

Loreal India Pvt. Ltd, Mumbai vs. Addl/Jt/Dy/ACIT/ITO/NFAC, Delhi

In the result, the appeal filed by the assessee for AY 2016-17 is treated as partly allowed

ITA 802/MUM/2022[2017-18]Status: DisposedITAT Mumbai29 Jun 2022AY 2017-18
Section 143(3)Section 144CSection 92C

A.Ys. 2016-17 & 2017-18 under section 143(3) read with section 144C of the Act in pursuance of direction given by learned Dispute Resolution Panel (DRP). 2. Since one of the issue urged in these appeals are identical in nature, they were heard together and are being disposed

L' Oreal India P. Ltd., Mumbai vs. National E-Assessment Centre/ Dy CIT-Circle-7(1)(1), Mumbai

In the result, the appeal filed by the assessee for AY 2016-17 is treated as partly allowed

ITA 1198/MUM/2021[2016-17]Status: DisposedITAT Mumbai29 Jun 2022AY 2016-17
Section 143(3)Section 144CSection 92C

A.Ys. 2016-17 & 2017-18 under section 143(3) read with section 144C of the Act in pursuance of direction given by learned Dispute Resolution Panel (DRP). 2. Since one of the issue urged in these appeals are identical in nature, they were heard together and are being disposed

Ca (India) Technologies P.Ltd, Mumbai vs. ITO RG 14(1)(2), Mumbai

Appeal is dismissed as withdrawn

ITA 2046/MUM/2017[2012-13]Status: DisposedITAT Mumbai29 Jun 2022AY 2012-13

Bench: Us Submitted That The Appellant Has Opted For Settlement Under The Provisions Of Direct Tax Vivad Se Vishwas Act, 2020 (Hereinafter Referred To As ‘The Dtvsv Act’). In This Regard, The Ld. Authorised Representative For The Appellant Placed On Record Order Of Full & Final Settlement Of Tax Arrears Under Section 5(2) Read With Section 6 Of The Dtvsv Act In Form 5 [Acknowledgement No. 347467521140322]. In View Of The Aforesaid, The Ld. Authorised Representative For The Appellant Requested For The Withdrawal Of The Present Appeal. The Learned Departmental Representative Did Not Have Any Objections To The Aforesaid Request.

For Appellant: Shri Yogesh MalpaniFor Respondent: Dr. Yogesh Kamat
Section 143(3)Section 144C(13)Section 144C(5)Section 5(2)Section 6

Income Tax Act, 1961 [hereinafter referred to as ‘the Act’] for the Assessment Year 2012-13, as per directions issued by Dispute Resolution Panel-1, Mumbai (hereinafter referred to as ‘the DRP’) under Section 144C(5) of the Act. Assessment Year: 2012-13 2. Ld. Authorised Representative for the Appellant