“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

M/S. Trianz Holdings Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, ground 34 is allowed

ITA 233/BANG/2021[2016-17]Status: DisposedITAT Bangalore30 May 2022AY 2016-17

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sit(Tp)A No.233/Bang/2021 Assessment Year : 2016-17 M/S. Trianz Holdings Pvt. Ltd., Acit, Vs. No.165/2, 6Th Floor, Kalyani Magnum, Circle – 7(1)(1), Doraisani Palya, Iim Post, Bengaluru. Bannerghatta Road, Bengaluru-560 076. Pan : Aafca 8051 P Appellant Respondent

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 14ASection 92BSection 92C

Learned Assessing Officer (“Learned AO”), Learned Transfer Pricing Officer (“Learned TPO”) and the Honourable IT(TP)A No.233/Bang/2021 Page 2 of 14 Dispute Resolution Panel (“Hon’ble DRP”) grossly erred in adjusting the transfer price of the Appellant’s international transactions with its Associated Enterprises

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 for statistical purposes

ITA 300/BANG/2021[2016-17]Status: DisposedITAT Bangalore26 May 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.300/Bang/2021 Assessment Year : 2016-17

For Appellant: Shri Sriram Sheshadri & Ms. Amulya K., CAsFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 143(3)

Impugned Order"), passed by the Ld. AO, to the extent it is not in conformity with the directions issued by the Hon'ble Dispute Resolution Panel ("Hon'ble DRP') under section 144C(5) of the Act ("DRP Directions"), is beyond jurisdiction, in contravention of the provisions

Mwh Uk Ltd, Mumbai vs. DCIT (It) 3(2)(2), Mumbai

ITA 6619/MUM/2017[2014-15]Status: DisposedITAT Mumbai25 May 2022AY 2014-15

Bench: Shri Shamim Yahya, Am & Shri Rahul Chaudhary, Jm Mwh Uk Ltd. Dcit (It)-3(2)(2) India Bulls Finance Centre, Mumbai Tower-3, 28Th Floor, Elphinstone Mills Compound, Vs. Senapati Bapat Marg, Elphinstone (W), Mumbai-400 013

Bench: These are appeals by the respective assessees against the respective orders of the Assessing Officer (A.O. for short) passed by the Dispute Resolution Panel-3 (WZ), Mumbai. Since the issues are common and connected and the appeals were heard together, these have been disposed of by this common order

ACIT 12(3)(2), Mumbai vs. Morgan Stanley Advantage Services P.Ltd, Mumbai

In the result, appeal of the Revenue is dismissed and Cross

ITA 1215/MUM/2016[2011-12]Status: DisposedITAT Mumbai24 May 2022AY 2011-12

Section 143(3)Section 144C(5)

u/s.143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (hereinafter referred to as ‘Act’), pursuant to the directions of the ld. Dispute Resolution Panel (DRP in short) u/s.144C(5) of the Act dated 27/11/2015 for the A.Y.2011-12. 1.1. Let us take up assessee’s Cross Objection No.55/Mum/2016 (A.Y.2011-12

M/S. Emerson Automation Solutions Intelligent Platforms Private Limited (Formerly M/S Ge Intelligent Platforms Private Limited), Bangalore vs. The Assistant Commissioner of Income Tax Circle-3(1)(2), Bangalore

In the result, grounds 10 and 11 are allowed for statistical purposes

ITA 356/BANG/2018[2013-14]Status: DisposedITAT Bangalore24 May 2022AY 2013-14

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm It(Tp)A No.356/Bang/2018 : Asst.Year 2013-2014 M/S.Emerson Automation The Assistant Commissioner Solutions Intelligent Platforms Of Income-Tax, Circle 3(1)(2) V. Bangalore. Private Limited (Formerly Known As M/S.Ge Intelligent Platforms Private Limited) Velankani Tech Park, Building 9 First Floor, 43 Hosur Road Bangalore 560 100 Pan : Aaacg7573K (Appellant) (Respondent) Appellant By : S/Sri.Sachit Jolly & Aayush Nagpal, Advocates Respondent By : Sri.Sumer Singh Meena, Cit-Dr Date Of Pronouncement : 24.05.2022 Date Of Hearing : 17.05.2022 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 30.10.2017 Passed U/S 143(3) R.W.S. 144C Of The I.T.Act. The Relevant Assessment Year Is 2013-2014. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company Engaged In The Business Of Process Industrial Automation That Includes Manufacture & Trading Of Automation Products, Solutions & Services For The Process Controlled Application. For The Relevant Assessment Year The Return Of Income Was Filed By The Assessee On 29.11.2013 Declaring Total Loss Of Rs.1,06,46,560. The 2 It(Tp)A No.356/Bang/2018 M/S.Emerson Automation Solutions Intelligent Platforms Pvt.Ltd Assessment Was Selected For Scrutiny By Issuance Of Notice U/S 143(2) Of The I.T.Act. During The 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 Transactions Undertaken By The Assessee With Its Associated Enterprises (Aes). The Tpo Vide Order Dated 31.10.2016 Passed U/S 92Ca Of The I.T.Act Proposed The Following Adjustments:- Segment Value Of Adjustment (Rs.) Manufacturing Segment 4,43,23,760 Hq Charges 86,39,654 Total 5,37,40,836

For Appellant: S/Sri.Sachit Jolly & Aayush Nagpal, AdvocatesFor Respondent: Sri.Sumer Singh Meena, CIT-DR

Section 143(2)Section 143(3)Section 71Section 92C

draft assessment order dated 26.12.2016 incorporating the above TP adjustments. Aggrieved by the draft assessment order, the assessee filed objections before the Dispute Resolution Panel (DRP). The DRP issued directions vide order dated 7.09.2007 primarily upholding the TP adjustment proposed by the TPO and the draft assessment. Pursuant

M/S. Ge Be Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 3(1)(2), Bangalore

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

ITA 2615/BANG/2019[2015-16]Status: DisposedITAT Bangalore23 May 2022AY 2015-16

Bench: Shri Chandra Poojari & Shri George K. George

For Appellant: Shri Sachit Jolly &For Respondent: Shri Sumer Singh Meena, D.R

Section 143(3)Section 92D

r.w.s. 144C(13) and 144C(5) of the Income-tax Act,1961 ['the Act' for short] consequent to the direction of Ld. Dispute Resolution Panel (“DRP”) dated 3.9.2019. The assessee has raised followings grounds of appeal:- Grounds:- IT(TP)A No.2615/Bang/2019 M/s. GE BE Pvt. Ltd., Bangalore Page ... Learned Deputy Commissioner of Income-tax, Circle 3(1)(2), Bangalore (`Assessing Office or 'AO') and the directions passed by the learned Dispute Resolution Panel (`DRP' or `the Panel'), to the extent prejudicial to the Appellant, is bad in law and liable to be quashed. 2. That on the facts

M/S. Wipro Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-7(1)(2), Bangalore

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

ITA 2556/BANG/2019[2015-16]Status: HeardITAT Bangalore23 May 2022AY 2015-16

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.2556/Bang/2019 Assessment Year : 2015-16

For Appellant: Shri S. Ganesh, Sr. ARFor Respondent: Shri T. Roumuan Paite, D.R

Section 143(3)

Income-tax Act,1961 ['the Act' for short] for assessment year 2015-16 in pursuance of directions given by Ld Dispute Resolution Panel (DRP). 2. The assessee is engaged in different types of business activities, viz., software development services and IT services; manufacture of Vanaspati/Hydro generated oils; toilet soaps; lighting ... details of their usage were not available, the Ld DRP declined to grant depreciation. The relevant observations made by the Ld Dispute Resolution Panel are extracted below:- “2.g With respect to the classification of assets and resultant treatment for applying correct rates the information is not sufficient

M/S Harman Connected Services Corporation India Pvt. Ltd., Bangalore vs. DCIT, Bangalore

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

ITA 705/BANG/2016[2011-12]Status: DisposedITAT Bangalore23 May 2022AY 2011-12

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A No.705/Bang/2016 Assessment Year : 2011-12 Dcit, M/S. Harman Connected Services Vs. Circle – 3(1)(2), Corporation India Private Limited, Bengaluru. (Formerly Known Symphony Teleca Corporation India Private Limited), Plot No.3 & 3A, Eoiz Industrial Area, Sy. No.85 & 86, Sadaramangala Village, Krishnarajapuram Hobli, Bengaluru – 560 066. Pan: Aabcg 5658 E Appellant Respondent Assessee By : Shri. T. Suryanarayana, Advocate Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 22.02.2022 Date Of Pronouncement : 23.05.2022 O R D E R Per B. R. Baskaran:

For Appellant: Shri. T. Suryanarayana, AdvocateFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

Section 10ASection 143(3)Section 40Section 40A

r.w.s 144C(13) of the Act for assessment year 2011-12 in pursuance of the directions given by Ld Dispute Resolution Panel (DRP). 2. The assessee herein is formerly known as Symphony Teleca Corporation India Private Limited. Prior to that, it was known as Symphony IT(TP)A No.705/Bang/2016 Page

Tesco Bangalore Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore

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

ITA 602/BANG/2016[2011-12]Status: PendingITAT Bangalore23 May 2022AY 2011-12

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A No.602/Bang/2016 Assessment Year : 2011-12 M/S. Tesco Bengaluru Private Limited, Dcit, Vs. (Earlier Known As Tesco Hindustan Service Circle – 7(1)(1), Centre Private Limited), Bengaluru. No.81 & 82, Tesco H S C, Epip Area, White Field, Bengaluru-560 066. Pan : Aabct 8915 B Appellant Respondent Assessee By : Shri. T. Suryanarayana, Advocate Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 22.02.2022 Date Of Pronouncement : 23.05.2022 O R D E R Per B. R. Baskaran:

For Appellant: Shri. T. Suryanarayana, AdvocateFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

Section 10ASection 143(3)Section 234BSection 234C

officer for assessment year 2011-12 u/s 143(3) r.w.s 144C(13) of the Act in pursuance of the directions given by Ld Dispute Resolution Panel (DRP). 2. At the time of hearing, the Ld Senior Advocate Shri T Suryanarayana, did not press Ground Nos. 1 to 17 relating

Fremantle India Television Productions Pvt Ltd., Mumbai vs. Asst CIT Circle- 16 (1), Mumbai

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

ITA 7894/MUM/2019[2015-16]Status: DisposedITAT Mumbai19 May 2022AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2015-16 Fremantle India Television The Asst. Commissioner Of Productions Private Limited, Income-Tax, Circle 16(1), 109, Shalimar Morya Park, Vs. Aayakar Bhavan, Plot B-2, Off New Link Road, Mumbai-400020. Oshiwara, Andheri West, Mumbai-400053. Pan No. Aaacf 0436 A Appellant Respondent Assessee By : Mr. M.P. Lohia/ Mr. Hemen Chadariya, Ars Revenue By : Dr. Satya Pinisetty, Cit-Dr Date Of Hearing : 16/03/2022 Date Of Pronouncement : 19/05/2022

For Appellant: Mr. M.P. Lohia/For Respondent: Dr. Satya Pinisetty, CIT-DR

Section 271

Asst. Commissioner of Income-Tax, Circle 16(1), Mumbai, pursuant to the direction of the Fremantle India Television Productions Private Limited 2 Ld. Dispute Resolution Panel (in short ‘the Ld. DRP’) for assessment year 2015-16. The grounds raised by the assessee in its appeal are reproduced as under

Emerson Electric Company (India)Pvt. Ltd, Mumbai vs. DCIT 1(2) (1) Jurisdictional Assessing Officer, Mumbai

ITA 933/MUM/2021[2016-17]Status: DisposedITAT Mumbai18 May 2022AY 2016-17

Bench: Shri Baskaran Br & Shri Kuldip Singhassessment Year: 2016-17

For Appellant: ShriDhanesh Bafna, A.RFor Respondent: Shri Rajesh Mishra, D.R

Section 144Section 153Section 92C

facts and in the circumstances of the case and in law, the Learned Assessing Officer (AO) based on the directions of the Dispute Resolution Panel (DRP), erred in confirming the action of the Learned Transfer Pricing Officer (TPO) in making Transfer Pricing (TP) adjustments

First Credit Ites P. Ltd, Mumbai vs. Addl/Jt.Dy/CIT/ITO, National E -Assessment Centre, Delhi

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

ITA 1183/MUM/2021[2016-17]Status: DisposedITAT Mumbai18 May 2022AY 2016-17

Bench: Shri Vikas Awasthy, Jm & Shri Prashant Maharishi, Am First Credit Ites P. Ltd. The Addl. Commissioner Of D-211, Ghatkopar Indl. Estate, Income-Tax Officer Behind R-City Mall, National E-Assessment Off L.B.S Marg, Vs. Centre, Ghatkopar West, Delhi-110003 Mumbai-400 086 (Appellant) (Respondent) Pan No.Aabcf5210B Assessee By : Shri Sunil Moti Lala, Ar Revenue By : Shri Tejinder Pal Singh, Dr Date Of Hearing: 22.02.2022 Date Of Pronouncement : 18.05.2022

For Appellant: Shri Sunil Moti Lala, ARFor Respondent: Shri Tejinder Pal Singh, DR

Section 143(3)Section 144BSection 144C(3)Section 144C(5)Section 92C

section 92CA(3) passed on 30th October 2019. 05. Consequently, a draft assessment order was passed and assessee filed objection before the learned Dispute Resolution Panel. The learned Dispute Resolution Panel after considering the objection of the assessee upheld the comparability study made by the learned Transfer Pricing First Credit ... ITES Pvt. Ltd.; AY 16-17 Officer. However, the assessee has requested before the learned Dispute Resolution Panel, the use of ‘other method’ as the most appropriate method for benchmarking of the transaction. Assessee also filed additional evidences. However, the learned Dispute Resolution Panel rejected the same for the reason

M/S. Intgreon Managed Solutions (India)P. Ltd., Mumbai vs. The Addl/Jt/Cy /CIT/Asstt./ITO-National E-Assessment Centre, Delhi, Mumbai

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

ITA 1023/MUM/2021[2015-16]Status: DisposedITAT Mumbai18 May 2022AY 2015-16

Section 147Section 234B

assessing officer u/s 147 r.w.s. 144C(13) of the Act for assessment year 2015-16 in pursuance of directions given by Ld Dispute Resolution Panel (DRP). 2. The Ld Counsel appearing for the assessee submitted that he is not pressing ground no.1 & 2. He submitted that the ground no.3 relating

Blackstone Fp Capital Partners Mauritius V Ltd., Mauritius vs. Dy CIT (International Taxation) Circle-1(2)(2), Mumbai

In the result, the appeals are allowed for statistical purposes in the terms indicated above

ITA 981/MUM/2021[2016-17]Status: FixedITAT Mumbai17 May 2022AY 2016-17

Section 143(3)Section 154

Indo Mauritius tax treaty will not be admissible. This stand of the Assessing Officer has also been confirmed by the Dispute Resolution Panel, and, infact reiterated, rationalized further, rephrased and, in a way thus, fortified. Taking note of the fact that no securities transaction tax (STT) was paid on this

Blackstone Fp Capital Partners Mauritius V Ltd., Mauritius vs. DCIT Intl Tax Cir.1(2), Mumbai

In the result, the appeals are allowed for statistical purposes in the terms indicated above

ITA 1725/MUM/2021[2016-17]Status: FixedITAT Mumbai17 May 2022AY 2016-17

Section 143(3)Section 154

Shipping Corporation of India Ltd., Mumbai vs. DCIT (Ltu)-Circle, Mumbai

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

ITA 30/MUM/2019[2014-15]Status: DisposedITAT Mumbai13 May 2022AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2014-15 The Shipping Corporation Of India Deputy Commissioner Of Limited, Income Tax (L.T.U.)-Circle-2, 245, Shipping House, Madam Cama Vs. 29Th Floor, Centre-2, World Road, Nariman Point, Trade Centre, Cuffe Parade, Mumbai-400021. Mumbai-400006. Pan No. Aaact 1524 F Appellant Respondent

For Appellant: Mr. Vinay Deshmane, ARFor Respondent: Mr. Vijay Shankar, CIT-DR

Section 115JSection 115VSection 143(3)Section 144C(13)Section 253(1)Section 28

referred as ‘the Assessing Officer’) for assessment year 2014-15, pursuant to The Shipping Corporation of India Ltd. 2 the direction of Ld. Dispute Resolution Panel (‘DRP’) dated 26.09.2018. 2. The grounds raised by the assessee in the appeal are reproduced as under : “The Appellant appeals against the impugned assessment ... without prejudice to each other. (1) The learned Deputy Commissioner of Income Tax - (L.T.U.) Circle-2, Mumbai ("the Id. AO”) and learned Dispute Resolution Panel-2 ('Id. DRP*), have erred in law and on facts and in circumstances of the case in excluding receipts aggregating to Rs.69

M/S. Ocwen Financial Solutions Private Limited, Bengaluru vs. Joint Commissioner of Income Tax, Special Range - 5, Bangalore

In the result appeal filed by the assessee stands partly allowed

ITA 2411/BANG/2019[2015-16]Status: DisposedITAT Bangalore13 May 2022AY 2015-16

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 2411/Bang/2019 Assessment Year : 2015-16 M/S. Ocwen Financial Solutions Pvt. Ltd., Pritech Park, Block 12, The Joint Commissioner Unit 2, 5B & 6A Floors, Of Income-Tax, Bellandur Village, Special Range-5, Sarjapur Marathahalli Bangalore. Ring Road, Vs. Bangalore – 560 103. Pan: Aaaco3764E Appellant Respondent : Shri K.R. Vasudevan & Assessee By Ms. Rashmi, Advocates : Dr. Manjunath Karkihalli, Revenue By Cit-Dr Date Of Hearing : 02-03-2022 Date Of Pronouncement : 13-05-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 24/09/2019 Passed By The Ld.Jcit, Special Range-5, Bangalore Under Section 143 (3) R.W.S 144C (13) Of The Act, For Assessment Year 2015-16 On Following Grounds Of Appeal: “I. Transfer Pricing The Grounds Mentioned Hereinafter Are Without Prejudice To One Another.

For Respondent: Shri K.R. Vasudevan &

Section 133(6)Section 143Section 92C

2411/Bang/2019 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 14,57,03,780/- with respect to the international transaction rendered by the Appellant under section 92CA

Xchanging Solutions Limited, Bangalore vs. The Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, grounds 20 to 23 are allowed for statistical purposes

ITA 294/BANG/2021[2016-17]Status: DisposedITAT Bangalore12 May 2022AY 2016-17

For Appellant: Sri.Padamchand Kincha, CAFor Respondent: Dr.Manjunath Karkaihalli, CIT-DR

Section 139(1)Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 40

Rs.50,20,109 by invoking the provisions of section 40(a)(i) of the I.T.Act. 3. Aggrieved, the assessee filed objections before the Dispute Resolution Panel (DRP). The DRP vide its directions dated 25.03.2021, partly allowed the objection raised by the assessee. Pursuant ot the directions of the DRP, final ... read with Section 144C(13) and Section 144B of the Income-tax Act, 1961 ("the Act") pursuant to the directions issued by the Dispute Resolution Panel ("DRP") under Section 144C(5) the Act inter-alia on the following grounds which are without prejudice to each other: On the facts

M/S. Shell Information Technology International B.V., Mumbai vs. Dy CIT (International Taxation)-4(2)(1), Mumbai

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

ITA 1245/MUM/2021[2017-18]Status: DisposedITAT Mumbai11 May 2022AY 2017-18

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur AgarwalFor Respondent: Ms. Surabhi Sharma, CIT–DR

Section 143(3)Section 144C(13)Section 2(24)Section 234B

Income-tax Act, 1961 (hereinafter referred to as the 'Act'), in pursuance of the directions issued by the Hon'ble Dispute Resolution Panel-2, (hereinafter referred to as the Hon'ble DRP') on the following grounds, each of which are without prejudice to one another: On the facts and circumstances ... nature of Royalty under the Act as well as under the DTAA. 5. Being aggrieved, the assessee filed detailed objections before the Learned Dispute Resolution Panel (“learned DRP”). Vide directions dated 17.03.2021, issued under section 144C(5) of the Act, learned DRP, inter– alia, after noting that the facts

M/S. Iqvia Ag (Previously Known As 'Ims Ag', Mumbai vs. Dy CIT (International Taxation)-2(2)(2), Mumbai

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

ITA 1203/MUM/2021[2016-17]Status: DisposedITAT Mumbai11 May 2022AY 2016-17

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur AgarwalFor Respondent: Shri Milind Chavan, Sr. DR

Section 143(3)Section 144C(13)Section 234BSection 9Section 9(1)Section 9(1)(vi)

Treaty ('Tax Treaty') 1. On the facts and in the circumstances of the case and in law, the Ld. Assessing Officer (AO) / Dispute Resolution Panel (DRP) erred in concluding that the Subscription Income received by the Appellant for providing access to its online database of statistically compiled pharmaceutical data collected ... further noted that similar finding of the Assessing Officer in assessment years 2013–14, 2014–15 and 2015–16 was upheld by the Dispute Resolution Panel (“DRP”). 6. The assessee filed detailed objections against the addition made by the Assessing Officer. Vide directions dated 15.03.2021, issued under section 144C