“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. United Spirits Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-7(1)(1), Bengaluru

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

ITA 2701/BANG/2017[2013-14]Status: DisposedITAT Bangalore04 Apr 2022AY 2013-14

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.2701/Bang/2017 : Asst.Year 2013-2014 M/S.United Spirits Limited The Deputy Commissioner Of Ub Towers, Income-Tax, Circle 7(1)(1) V. No.24 Vittal Mallya Road Bangalore. Bangalore – 560 001. Pan : Aaccm8043J. (Appellant) (Respondent) Appellant By : Sri.Percy Pardiwala, Senior Advocate Respondent By : Sri.Pradeep Kumar, Cit-Dr Date Of Pronouncement : 05.04.2022 Date Of Hearing : 24.03.2022 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 12.10.2017 Passed U/S 143(3) R.W.S. 144C(13) 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 Manufacture & Sale Of Alcoholic Beverage. The Assessee Filed Its Return Of Income For The Assessment Year 2013-2014 On 28.11.2013 Which Was Selected For Scrutiny Assessment. During The Course Of Assessment, The Assessee’S Case Was Also Referred To The Transfer Pricing Officer (Tpo). The Tpo Vide Order Dated 26.10.2016, Recommended Transfer Pricing Adjustments. The A.O., Thereafter, Passed A Draft Assessment Order Dated 30.12.2016. 2 It(Tp)A No.2701/Bang/2017 M/S.United Spirits Limited.

For Appellant: Sri.Percy Pardiwala, Senior AdvocateFor Respondent: Sri.Pradeep Kumar, CIT-DR

Section 143(3)Section 14ASection 234BSection 234CSection 36(1)(iii)

No.2701/Bang/2017 M/s.United Spirits Limited. 3. Aggrieved by the adjustments proposed in the draft assessment order, the assessee filed its objections before the Dispute Resolution Panel (DRP). The DRP vide its directions dated 18th September, 2017 disposed of the assessee’s objections. Pursuant to the DRP’s directions, the AO passed

Iss Facility Services India Private Limited, Mumbai vs. Assistant Commissioner of Income Tax 10(1)(2), Mumbai

In the result, appeal by the assessee is partly allowed in the terms of aforesaid

ITA 411/MUM/2018[2013-14]Status: DisposedITAT Mumbai01 Apr 2022AY 2013-14

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं.411/मुं/2018 ("न. व. 2013-14) Iss Facility Services India Private Limited The Qube, B 401/404 & A 402 Behind Taj Stats, Village Marol Sahar Road, Andheri (East) Mumbai – 400 059 ..... अपीलाथ" /Appellant Pan: Aabc13815M बनाम/Vs. The Assistant Commissioner Of Income Tax- 10(1)(2) Room No. 14, 20Th Floor, Air India Building, ..... ""तवाद"/Respondent Nariman Point, Mumbai – 400 021

For Appellant: Shri. M.P. Lohia with Shri. Nikhil TiwariFor Respondent: Shri Yogesh Kamat, CIT- DR

Section 143(3)Section 92C

Officer (‘AO’) passed the draft assessment order dated 29.12.2016, inter-alia, on the basis of adjustment proposed by the TPO. 3.4 Before the Dispute Resolution Panel (‘DRP’), the assessee filed objections, inter- alia, against the adjustment proposed by TPO / AO. The DRP vide directions dated 29.09.2017, rejected assessee’s objections

DCIT(It)-2(1)(1), Mumbai vs. Clsa Ltd., Mumbai

In the result, the Cross Objections filed by the assessee for both the A

ITA 592/MUM/2019[2013-14]Status: DisposedITAT Mumbai31 Mar 2022AY 2013-14

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant (Accoutant Member)

For Appellant: Mr. Paras Savla, ARFor Respondent: Mr. Anand Mohan, DR

Section 271(1)(c)Section 274

reimbursement for services received by the assessee from its Associated Enterprises as fee for technical services (FTS) following the finding of the ld. Dispute Resolution Panel (DRP) in assessment year 2011-12. In A.Y. 2011-12, the assessee did not prefer appeal against the finding of ld. DRP in this ... Rs.47,90,32,670/- to tax in India for A.Y. 2012-13. The assessee did not file any objection before the ld. Dispute Resolution Panel (for short ‘DRP’) against the draft assessment order and accepted the said reimbursement as FTS. The facts in respect of A.Y. 2013-14 are also

M/S. Infineon Technologies India Pvt Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bengaluru

In the result the appeal filed by assessee stands allowed partly

ITA 2870/BANG/2017[2013-14]Status: DisposedITAT Bangalore31 Mar 2022AY 2013-14

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiit(Tp)A No.2870/Bang/2017 Assessment Year: 2013-14 M/S. Infineon Technologies India Pvt. Ltd. Deputy Commissioner 9Th Floor Prestige Of Income-Tax Thirulakshmi Vs. Circle-3(1)(1) No.11 M.G. Road Bengaluru Bengaluru 560 001 Pan No : Aabcs6967N Appellant Respondent Appellant By : Shri K.R. Vasudevan, A.R. Shri Sumer Singh Meena, Respondent By : D.R. Date Of Hearing : 13.01.2022 Date Of Pronouncement : 31.03.2022 O R D E R Per Beena Pillai: Present Appeal Is Filed By Assessee Against The Order Dated 16/10/2017 Passed By The Ld.Dcit Under Section 143(3) R.W. Section 144C(13) For Assessment Year 2013-14 On Following Grounds Of Appeal: “The Grounds Mentioned Hereinafter Are Without Prejudice To One Another.

For Appellant: Shri K.R. Vasudevan, A.R

Section 133(6)Section 143(3)Section 144C(13)Section 40Section 92C

Page 2 of 32 A. Transfer Pricing 1. The learned Assessing Officer ("learned AO"), learned Transfer Pricing Officer ("learned TPO") ark! the Honourable Dispute Resolution Panel ("Hon'ble DRP") grossly erred in adjusting the transfer price by INR 6,15,17,368/- with respect to the international transactions rendered

M/S Tyco Fire & Security India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle-7(1)(1), Bangalore

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

ITA 3363/BANG/2018[2014-15]Status: DisposedITAT Bangalore30 Mar 2022AY 2014-15

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 3363/Bang/2018 Assessment Year : 2014-15 M/S. Tyco Fire & The Assistant Security India Pvt. Ltd., Commissioner Of D-601, Rmz Contennial, Income Tax, Kundalahalli Main Road, Circle – 7 (1)(1), Bangalore – 560 048. Vs. Bangalore. Pan: Aabct0087C Appellant Respondent Assessee By : Shri Rajan Vora, Ca : Shri Sumer Singh Meena, Cit Revenue By Dr (Osd) Date Of Hearing : 05-01-2022 Date Of Pronouncement : 30-03-2022 Order Per Beena Pillaipresent Appeal Has Been Filed By Assessee Against The Final Assessment Order Dated 26.10.2018 Passed By The Ld.Acit, Circle – 7(1)(1), Bangalore For Assessment Year 2014-15 On Following Grounds Of Appeal. “Based On The Facts & Circumstances Of The Case & In Law, Tyco Fire & Security India Private Limited (Hereinafter Referred To As "The Appellant"), Respectfully Craves Leave To Prefer An Appeal Against The Appeal Order Passed By The Learned Assessing Officer (Hereinafter Referred To As The "Learned Ao") Dated October 26, 2018 Under Section 143(3) Read With Section 144C Of The Income-Tax Act, 1961 ("The Act") Pursuant To The Directions Dated September 20, 2018 Issued By The Dispute Resolution Panel (Hereinafter Referred To As The "Drp") U/S 144C (5) Of The Act (`The Impugned Order') Inter-Alia On The Following Grounds: That On The Facts & Circumstances Of The Case & In Law:

For Appellant: Shri Rajan Vora, CA

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

read with section 144C of the Income-tax Act, 1961 ("the Act") pursuant to the directions dated September 20, 2018 issued by the Dispute Resolution Panel (hereinafter referred to as the "DRP") u/s 144C (5) of the Act (`the Impugned order') inter-alia on the following grounds: That

Tata Power Solar Systems Limited, Bangalore vs. DCIT, Bangalore

In the result, the appeal filed by the assessee stands allowed on the legal issue

ITA 699/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Mar 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 548/Bang/2016 Assessment Year : 2011-12 M/S. Tata Power Solar The Deputy Systems Ltd., Commissioner Of 78, Electronic City, Income Tax, Hosur Road, Circle – 7(1)(1), Bangalore – 560 100. Bangalore. Vs. Pan: Aaact4660J Appellant Respondent & It(Tp)A No. 699/Bang/2016 Assessment Year : 2011-12 (By Assessee) Assessee By : Shri Kanchun Kaushal, Ca : Shri Manjunath Karkihalli, Revenue By Cit-Dr Date Of Hearing : 14-02-2022 Date Of Pronouncement : 30-03-2022 Order Per Beena Pillaipresent Cross Appeals By Assessee & Revenue Arises Out Of Final Assessment Order Dated 28.01.2016 Passed By The Ld.Dcit, Circle -7 (1)(1), Bangalore For Assessment Year 2011-12 On Following Grounds Of Appeal: It(Tp)A No. 548/Bang/2016 (Revenue’S Appeal): “1. The Directions Of The Dispute Resolution Panel Are Opposed To Law & Facts Of The Case.

For Appellant: Shri Kanchun Kaushal, CA

Section 144C

Assessment Year 2011-12 on following grounds of appeal: IT(TP)A No. 548/Bang/2016 (Revenue’s appeal): “1. The directions of the Dispute Resolution Panel are opposed to law and facts of the case. Page 2 of 17 IT(TP)A Nos. 548 & 699/Bang/2016 2. Whether ... case. 3. For these and other grounds that may be argued at the time of hearing, it is prayed that the directions of Dispute Resolution Panel in so far as it relates to the above grounds may be reversed. 4. The appellant craves leaves to add, alter, amend

DCIT, Bangalore vs. M/S Tata Power Solar Systems Ltd., Bangalore

In the result, the appeal filed by the assessee stands allowed on the legal issue

ITA 548/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Mar 2022AY 2011-12

For Appellant: Shri Kanchun Kaushal, CA

Section 144C

Idhasoft Ltd, Navi Mumbai vs. DCIT 10(3), Mumbai

In the result, both the appeals of the assessee are dismissed, as not maintainable

ITA 6329/MUM/2014[2009-10]Status: DisposedITAT Mumbai29 Mar 2022AY 2009-10

Bench: Shri M. Balaganesh () & Shri Kuldip Singh ()

Section 144C(5)

1 ITA 6329/Mum/2014 ITA 1218/Mum/2015 IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “K”, MUMBAI BEFORE SHRI M. BALAGANESH (ACCOUNTANT

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

In the result, the appeal is partly allowed

ITA 129/BANG/2019[2014-15]Status: DisposedITAT Bangalore29 Mar 2022AY 2014-15

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year :2014-15 M/S. Continental Automotive Vs. Dcit, Components India Pvt. Ltd., Circle – 2(1)(1), Plot No.53B, Bommasandra Industrial Bengaluru. Area, Hosur Road, Attibele Hobli, Anekal Taluk, Bengaluru–560 099. Pan : Aakcs 9578 C Appellant Respondent Assessee By : Shri. T. Suryanarayana, Senior Advocate Revenue By : Shri. Mudavathu Harish Chandra Naik, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 21.03.2022 Date Of Pronouncement : 29.03.2022 O R D E R

For Appellant: Shri. T. Suryanarayana, Senior AdvocateFor Respondent: Shri. Mudavathu Harish Chandra Naik, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 92

passes a draft order of assessment against which, the Assessee has a right to file objections before the Dispute Resolution Panel (DRP) u/s.144C of the Act. Under section 144C(5), the Dispute Resolution Panel (DRP) shall issue the directions, as it thinks fit, for the guidance ... aforesaid determination of ALP by the TPO in the draft order of Assessment by the AO, the Assessee filed objections before the Dispute Resolution Panel (DRP) u/s.144C of the Act. The DRP issued directions, whereby it upheld the contentions of the TPO, subject to the following directions: Continental Automotive Components

Givaundan(India) Pvt. Ltd., Bangalore vs. ACIT, Ltu Cr 1, Bangalore

In the result the appeal filed by assessee stands allowed for statistical purposes

ITA 229/BANG/2015[2010-2011]Status: DisposedITAT Bangalore29 Mar 2022AY 2010-2011

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiit(Tp)A No. 229/Bang/2015 Assessment Year : 2010-11 M/S. Givaudan (India) The Assistant Pvt. Ltd., Commissioner Of Plot No. 26, 2Nd Cross, Income Tax, Jigani Industrial Area, Ltu, Bangalore – 562 106. Circle – 1, Vs. Pan: Aaacv7454J Bangalore. Appellant Respondent Assessee By : Shri Sumeet Khurana, Ca : Shri Sumer Singh Meena, Cit- Revenue By I Date Of Hearing : 11-01-2022 Date Of Pronouncement : 29-03-2022 Order Per Beena Pillaiit Is Submitted That The Main Appeal Was Heard By This Tribunal & Order Was Passed On 02/08/2019. However Grounds 6 & 7 Were Not Adjudicated Independently For Assessment Year 2010- 11. The Assessee Preferred Mp No.15/Bang/2020 Requesting For Adjudication Of These Grounds. 2. Accordingly The Present Appeal Is Fixed For Hearing For Adjudication Of Following Grounds: “6. That The Learned Ao & The Learned Panel Erred Both In Facts & Law In Confirming The Action Of The Learned Tpo Of Making An Adjustment To The Transfer Price Of The Appellant In Respect Of The Payment Of Royalty By Rs.27,67,42,242, Holding That The International Transaction

For Appellant: Shri Sumeet Khurana, CA

length price ("ALP") o f royalty as NIL by applying CUP method and proposed an adjustment of INR 276,742,242. The learned Dispute Resolution Panel (learned Panel') upheld the findings of learned TPO on the basis that except stating that the payment was made as per the license agreement

Deputy Commissioner of Income Tax, Trust Circle- 3(1), Bangalore vs. M/S. Baldwin Boys High School, Bangalore

ITA 606/BANG/2001[1997-98]Status: DisposedITAT Bangalore24 Mar 2022AY 1997-98

For Appellant: Shri V. Srinivasan, Advocate

Section 10(22)Section 143(2)Section 234Section 253Section 253(4)

Deputy Commissioner (Appeals) or, as the case may be, the Commissioner (Appeals) or the Assessing Officer in pursuance of the directions of the Dispute Resolution Panel has been preferred under sub-section (1) or sub- section (2) or sub-section (2A) by the other party, may, notwithstanding that ... objections, verified in the prescribed manner, against any part of the order of the Assessing Officer (in pursuance of the directions of the Dispute Resolution Panel) or Deputy Commissioner (Appeals) or, as the case may be, the Commissioner (Appeals), and such memorandum shall be disposed of by the Appellate Tribunal

Accenture Solution Pvt. Ltd, Mumbai vs. DCIT, Circle 14(1)(1), Mumbai

In the result, appeal by assessee is allowed in the terms aforesaid

ITA 7457/MUM/2018[2014-15]Status: DisposedITAT Mumbai23 Mar 2022AY 2014-15

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं. 7457/मुं/2018 ("न. व. 2014-15 ) Accenture Solutions Private Limited(‘Asol) [As A Successor To Accenture Services Private Limited (“Aspl”) Which Has Merged Into Asol With An Effective Date Of 1 December 2016] Plant 3, Godrej & Boyce Complex, Phirojshah Nagar, Vikhroli West, Off Lbs Marg, Mumbai 400 079. Pan: Aaach-3235-M ...... अपीलाथ" /Appellant बनाम Vs. The Deputy Commissioner Of Income Tax, Circle 14(1)(1), Aaykar Bhavan, M.K.Road, Mumbai 400 021 ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : Shri Percy J. Pardiwalla, Sr. Advocate With Shri Hiten Chande ""तवाद" "वारा/Respondent By : Dr.Yogesh Kamat Cit Dr & Shri Satya Pinisetty सुनवाई क" "त"थ/ Date Of Hearing : 01/02/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 23/03/2022 आदेश/ Order Per Vikas Awasthy, Jm:

For Appellant: Shri Percy J. Pardiwalla, Sr. Advocate with Shri Hiten ChandeFor Respondent: Dr.Yogesh Kamat CIT DR &

Section 143(2)Section 143(3)Section 144C(13)Section 92C

draft assessment order was passed in the name of erstwhile company which had ceased to exist. Thereafter, the assessee filed objections before the Dispute Resolution Panel (DRP). The DRP issued directions dated 04/09/2018 in the correct name i.e. M/s. Accenture Solutions Pvt. Ltd. Consequent to the directions

Dhl Logistics P.Ltd, Mumbai vs. DCIT Cir 9(3)(1), Mumbai

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

ITA 7286/MUM/2018[2014-15]Status: DisposedITAT Mumbai23 Mar 2022AY 2014-15

Bench: Shri Pramod Kumar & Shri Pavan Kumar Gadaledhl Logistics Pvt Ltd Vs. Acit – 9(3)(1) 201A, Silver Utopia, Room No. 215, Cardinal Gracias Road 2Nd Floor, Aayakar Chakala, Andheri (E) Bhavan, M.K.Road, Mumbai – 400099 Mumbai – 400020 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacm6824A Appellant .. Respondent Appellant By : Shri. Madhur Agarwal.Ar Respondent By : Dr. Yogesh Kamat.Cit.Dr Date Of Hearing 27.01.2022 Date Of Pronouncement 15.03.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm:

For Appellant: Shri. Madhur Agarwal.ARFor Respondent: Dr. Yogesh Kamat.CIT.DR

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

final assessment order u/s 143(3) r.w.s 144C(13) of the Income Tax Act, 1961 passed in pursuance to directions of the Dispute Resolution Panel (DRP) u/s 144C(5) of the Act.The assessee has raised the following grounds of appeal: 1. On the facts and circumstances of the case ... Dispute Resolution Panel ('DRP') erred in upholding the action of the Ld. Assessing Officer ('AO') / Ld. Transfer Pricing DHL Logistics P Ltd, Mumbai. Officer (TPO) in confirming the addition of INR 37,53,73,494 /- to the income of the Appellant by holding that its international transactions pertaining

M/S Brady Company India Private Limited, Bangalore vs. Income Tax Officer Ward-1(1)(4), Bangalore

In the result, ground 26 is allowed for statistical purposes

ITA 790/BANG/2019[2014-15]Status: DisposedITAT Bangalore22 Mar 2022AY 2014-15

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.103/Bang/2019 : Asst.Year 2014-2015 It(Tp)A No.790/Bang/2019 : Asst.Year 2014-2015 M/S.Brady Company India Private The Income Tax Officer Limited, No.26, Survey No.41 Ward 1(1)(4) V. Bengaluru. Konappana Agrahara Village Begur, Hobli, Electronci City, Phase-Ii, Bengaluru – 560 100. Pan : Aaccb8163A (Appellant) (Respondent) Appellant By : Sri.K.R.Vasudevan, Advocate Respondent By : Sri.Pradeep Kumar, Cit-Dr Date Of Pronouncement : 22.03.2022 Date Of Hearing : 07.03.2022 O R D E R Per George George K, Jm : These Appeals Are At The Instance Of The Assessee. The Relevant Assessment Year Is 2014-2015. 2. The Reason For Filing Two Appeals For Assessment Year 2014-2015 Is That Pursuant To The Dispute Resolution Panel’S (Drp) Directions (Directions Dated 28.09.2008), The A.O. Passed Final Assessment Order U/S 143(3) R.W.S. 144C Of The I.T.Act Dated 15.11.2018. In The Said Assessment Order, The Aggregate Transfer Pricing Adjustment Was Determined At Rs.14,43,51,081. An Appeal Has Been Filed Before The Tribunal Against The Order U/S 143(3) R.W.S. 144C Of The I.T.Act (Appeal No.It(Tp)A No.103/Bang/2019). Subsequently, On Application By The Assessee, The Drp Passed Rectification Order Dated

For Appellant: Sri.K.R.Vasudevan, AdvocateFor Respondent: Sri.Pradeep Kumar, CIT-DR

Section 143(3)Section 154

relevant assessment year is 2014-2015. 2. The reason for filing two appeals for assessment year 2014-2015 is that pursuant to the Dispute Resolution Panel’s (DRP) directions (directions dated 28.09.2008), the A.O. passed final assessment order u/s 143(3) r.w.s. 144C of the I.T.Act dated

M/S Brady Company India Private Limited, Bangalore vs. Income Tax Officer Ward-1(1)(4), Bangalore

In the result, ground 26 is allowed for statistical purposes

ITA 103/BANG/2019[2014-15]Status: DisposedITAT Bangalore22 Mar 2022AY 2014-15

For Appellant: Sri.K.R.Vasudevan, AdvocateFor Respondent: Sri.Pradeep Kumar, CIT-DR

Section 143(3)Section 154

M/S Lenovo India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle-4(1)(1), Bangalore

In the result, the appeal filed by assessee stands allowed

ITA 2833/BANG/2017[2013-14]Status: DisposedITAT Bangalore21 Mar 2022AY 2013-14

For Appellant: Shri Padamchand Khincha, CA

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

Section 143(3) read with Section 144C(13) of the Income-tax Act, 1961 ("the Act"), the Directions issued by the Hon'ble Dispute Resolution Panel ("Hon'ble DRP") and the Order of the learned Transfer Pricing Officer ("learned TPO") issued under Section 92CA

Toyota Industries Engine India Private Limited, Bangalore vs. DCIT, Bangalore

In the result, appeal by the assessee is partly allowed

ITA 355/BANG/2016[2011-12]Status: DisposedITAT Bangalore21 Mar 2022AY 2011-12

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A Nos.355, 2127/Bang/2016 Assessment Years : 2011-12, 2012-13 It(Tp)A No. & Appellant Respondent Assessment Year M/S. Toyota Industries Engine India Dcit, 355/Bang/2016 Private Limited, Circle – 4(1)(1), (Formerly Known As Kirloskar Toyota Bengaluru. Textile Machinery Private Limited), Plot No.9, Phase – 2, Jigani Industrial Area, Jigani, Bengaluru-560 105. Pan : Aaack 7425 Q -Do- Dcit, 2127/Bang/2016 Circle – 7(1)(1), Bengaluru.

For Appellant: Shri. Ajit Tolani/Darpan Kirpalani, CAFor Respondent: Shri. Roumuan Paite, CIT(DR)(ITAT), Bengaluru

Section 115JSection 143(3)

circumstances of the case and in law, the Deputy Commissioner of Income-tax, Circle 4(1)(1), Bangalore (‘Learned AO’) / Hon'ble Dispute Resolution Panel (`lIon'ble DRP) erred in not allowing deduction under the provisions of the Income Tax Act, 1961, on account of Education Cess and Secondary

M/S.Toyota Industries Engine India Private Limited, Bangalore vs. Deputy Commissioner of Income-Tax, Bangalore

In the result, appeal by the assessee is partly allowed

ITA 2127/BANG/2016[2012-13]Status: DisposedITAT Bangalore21 Mar 2022AY 2012-13

For Appellant: Shri. Ajit Tolani/Darpan Kirpalani, CAFor Respondent: Shri. Roumuan Paite, CIT(DR)(ITAT), Bengaluru

Section 115JSection 143(3)

M/S.Goldman Sachs Services Private Limited, Bangalore vs. Asst. Commissioner of Income Tax, Bangalore

In the result, appeal by the assesse is partly allowed

ITA 474/BANG/2017[2012-13]Status: DisposedITAT Bangalore11 Mar 2022AY 2012-13

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A No.474/Bang/2017 Assessment Year : 2012-13 Goldman Sachs Services Pvt. Ltd., Acit, Vs. Crystal Downs, Embassy Golf Links Business Circle – 3(1)(2), Park, Off Intermediate Ring Road, Bengaluru. Bengaluru-560 071. Pan : Aaccg 2435 N Assessee Respondent Assessee By : Shri. Madhur Agarwal, Advocate Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 07.03.2022 Date Of Pronouncement : 11.03.2022 O R D E R Per N V Vasudevan

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

Section 143(3)Section 14A

filed concise grounds of appeal which reads as follows: 1. Transfer Pricing (Information Technology Enabled services segment) The order passed by the Honorable Dispute Resolution Panel ("DRP") and the learned Assessing Officer ("AO")/ Transfer Pricing Officer ("TPO") is not in accordance with the law and is IT(TP)A No.474/Bang/2017 ... assessee has also filed an application for admission of the following additional ground: “The Learned Assessing Officer ("Learned AO") and Hon'ble Dispute Resolution Panel ("Hon'ble DRP"), while assessing the total income of the Appellant for the year under consideration, ought to have allowed a deduction for education cess

M/S. Transworld Ict Solutions (P) Ltd., Bangalore vs. DCIT, Bangalore

In the result, the appeal for Assessment Year 2005-06 is partly allowed

ITA 1308/BANG/2010[2005-06]Status: DisposedITAT Bangalore11 Mar 2022AY 2005-06

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A Nos.1305 To 1308/Bang/2010 Assessment Years : 2002-03, 2003-04, 2004-05, 2005-06 Dcit, M/S. Transworld Ict Solutions Pvt. Ltd., Vs. No.15, Hoody, Whitefield Road, Central Circle – 2(1), Mahadevapura Road, Bengaluru. Bengaluru – 560 048. Pan : Aabct 3824 F Assessee Respondent Assessee By : Shri. G. S. Prashanth, Ca Revenue By : Shri. Dilip, Advocate, Standing Counsel For Department Date Of Hearing : 03.03.2022 Date Of Pronouncement : 11.03.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. G. S. Prashanth, CAFor Respondent: Shri. Dilip, Advocate, Standing Counsel for Department

Section 132Section 143(3)Section 153ASection 92C(2)

suggested by the TPO was incorporated by the AO in the draft Order of Assessment against which the assessee filed objections before the Dispute Resolution Panel (DRP). The DRP confirmed the action of the TPO. The AO incorporated the additions suggested by the TPO in the final Order of assessment