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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

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 1307/BANG/2010[2004-05]Status: DisposedITAT Bangalore11 Mar 2022AY 2004-05

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

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 1306/BANG/2010[2003-04]Status: DisposedITAT Bangalore11 Mar 2022AY 2003-04

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

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 1305/BANG/2010[2002-03]Status: DisposedITAT Bangalore11 Mar 2022AY 2002-03

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

Oriental Aromatics Ltd, Mumbi, Mumbai vs. DCIT CC 1(2)(2), Mumbai

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

ITA 6331/MUM/2019[2014-15]Status: DisposedITAT Mumbai10 Mar 2022AY 2014-15
Section 143(3)Section 4Section 92(1)

earlier years. During the course of appellate proceedings the appellant submitted that the identical issue was involved in AY 2013-14 where Learned Dispute Resolution Panel- 2 Mumbai (DRP) has upheld the transfer pricing adjustment in respect of interest free loan, however, the Panel directed the AO to apply interest

V2 Tech Ventures P.Ltd, Navi Mumbai vs. DCIT 15(3)(1), Mumbai

In the result, the appeal is allowed for statistical purposes in the terms indicated above

ITA 777/MUM/2016[2011-12]Status: DisposedITAT Mumbai10 Mar 2022AY 2011-12
Section 143(3)

respect of provision for software development services, and that the Transfer Pricing Officer erred in recommending the said ALP adjustment and the Dispute Resolution Panel erred in confirming the said ALP adjustment. The twelve grounds of appeal, set out in summarized grounds of appeal, are primarily arguments in support ... been done at the entity level and the arm’s length adjustment is computed. 4. Aggrieved, assessee raised the objections before the Dispute Resolution Panel but without any success by making a rather cryptic observation as follows:- On the basis of above finding, the TPO rejected the segmental audit report

Icici Bank Ltd., Mumbai vs. The Dy CIT -2(3)(1), Mumbai

In the result we hold that the learned principal

ITA 737/MUM/2021[2011-12]Status: DisposedITAT Mumbai08 Mar 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Icici Bank Limited The Dy. Commissioner Of Icici Bank Towers, Income-Tax-2(3)(1), Aayakar Bhavan, 5 Th Floor, Bandra Kurla Complex, Vs. Bandra (East), Room No.552, Mumbai-400 051 M.K.Road, Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaaci1195H Appellant By : Ms Arati Vissanji, Ar Respondent By : Shri Nikhil Chaudhary, Cit Dr Date Of Hearing: 13.01.2022 Date Of Pronouncement : 08.03.2022

For Appellant: Ms Arati Vissanji, ARFor Respondent: Shri Nikhil Chaudhary, CIT DR
Section 143(3)Section 147Section 263Section 263(1)Section 263(2)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

case of the assessee was taken up for scrutiny. Draft assessment order was passed. As assessee did not want to approach Dispute Resolution Panel, final assessment order under section 143(3) read with section 144C(3) of the Act was passed on 25th March, 2015 determining the total income

Ups Asia Group Pte Ltd., Mumbai vs. Asstt. CIT (International Taxation)-4(3)(1), Mumbai

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

ITA 1220/MUM/2021[2017-18]Status: DisposedITAT Mumbai08 Mar 2022AY 2017-18

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Milind S. Chavan, Sr. AR
Section 143(3)Section 144CSection 144C(13)Section 9(1)(i)

attributed profit of Rs.2,09,53,496 to the said P.E. of the assessee in India. 5. The assessee filed objections before the Dispute Resolution Panel (hereinafter referred to as ―the DRP‖) against the addition proposed in the draft assessment order. The DRP, vide its directions dated 17.03.2021, following

M/S. Vee Technologies Private Limited, Bangalore vs. Principal Commissioner of Income Tax, Bengaluru-7, Bengaluru

In the result, appeal of the assessee is partly allowed

ITA 7/BANG/2022[2014-15]Status: DisposedITAT Bangalore07 Mar 2022AY 2014-15

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year : 2014-15 M/S. Vee Technologies Pvt. Ltd., Vs. The Principal Commissioner Of Income Tax, No.71, Sona Towers, Millers Road, Bengaluru – 7, Bengaluru – 560 052. Bengaluru. Pan : Aabcv 0100 C Appellant Respondent It(Tp)A No.2042/Bang/2019 Assessment Year : 2014-15 M/S. Vee Technologies Pvt. Ltd., Vs. Ito, No.71, Sona Towers, Millers Road, Ward – 7[1][2], Bengaluru – 560 052. Bengaluru. Pan : Aabcv 0100 C Appellant Respondent Appellant By : Shri. Suresh Muthukrishna, Ca Respondent By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 02.03.2022 Date Of Pronouncement : 07.03.2022 O R D E R Per N. V. Vasudevan:

For Appellant: Shri. Suresh Muthukrishna, CAFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 10BSection 143(3)Section 263Section 92C

Order of Assessment was passed on 31.08.2018 and the assessee approached the present Counsel Mr. Suresh Muthukrishna, CA, to file objection before the Dispute Resolution Panel (DRP). The DRP gave its direction on 28.05.2019. Pursuant to the directions of the DRP, the AO passed the final order of assessment dated

M/S. Vee Technologies Private Limited, Bengaluru vs. The Income Tax Officer, Ward- 7(1)(2), Bengaluru

In the result, appeal of the assessee is partly allowed

ITA 2042/BANG/2019[2014-15]Status: DisposedITAT Bangalore07 Mar 2022AY 2014-15

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year : 2014-15 M/S. Vee Technologies Pvt. Ltd., Vs. The Principal Commissioner Of Income Tax, No.71, Sona Towers, Millers Road, Bengaluru – 7, Bengaluru – 560 052. Bengaluru. Pan : Aabcv 0100 C Appellant Respondent It(Tp)A No.2042/Bang/2019 Assessment Year : 2014-15 M/S. Vee Technologies Pvt. Ltd., Vs. Ito, No.71, Sona Towers, Millers Road, Ward – 7[1][2], Bengaluru – 560 052. Bengaluru. Pan : Aabcv 0100 C Appellant Respondent Appellant By : Shri. Suresh Muthukrishna, Ca Respondent By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 02.03.2022 Date Of Pronouncement : 07.03.2022 O R D E R Per N. V. Vasudevan:

For Appellant: Shri. Suresh Muthukrishna, CAFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 10BSection 143(3)Section 263Section 92C

Order of Assessment was passed on 31.08.2018 and the assessee approached the present Counsel Mr. Suresh Muthukrishna, CA, to file objection before the Dispute Resolution Panel (DRP). The DRP gave its direction on 28.05.2019. Pursuant to the directions of the DRP, the AO passed the final order of assessment dated

Altran Technologies India Pvt Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-1(1)(1), Bengaluru

In the result the appeal filed by assessee stands partly allowed

ITA 2904/BANG/2017[2013-14]Status: DisposedITAT Bangalore07 Mar 2022AY 2013-14

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiit(Tp)A No. 2904/Bang/2017 Assessment Year : 2013-14 M/S. Altran Technologies India Pvt. Ltd., C/O Ernst & Young Llp, The Deputy Ground & 1St Floor, Commissioner Of Income ‘A’ Wing, Divyasree Chambers, Tax, Vs. #11, O’ Shaughnessy Road, Circle – 1 (1)(1), Langford Gardens, Bangalore. Bangalore – 560 025. Pan: Aaaca7125R Appellant Respondent Assessee By : Shri Nageswar Rao, Advocate Revenue By : Shri Pradeep Kumar, Cit-Dr Date Of Hearing : 27-12-2021 Date Of Pronouncement : 07-03-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 31/10/2017 Passed By The Ld.Dcit, Circle – 1(1)(1), Bangalore For Assessment Year 2013-14 On Following Grounds Of Appeal: “Based On The Facts & Circumstances Of The Case & In Law, Altran Technologies India Private Limited (The 'Appellant') Respectfully Craves Leave To Prefer An Appeal Against The Order Passed By The Learned Assessing Officer (Hereinafter Referred To As The 'Id. Ao') Under Section 143(3) Read With Section 144C Of The Income-Tax Act, 1961 (The 'Act') Pursuant To The Directions Issued By The Hon'Ble Dispute Resolution Panel (`Drp') On The Following Grounds:

For Appellant: Shri Nageswar Rao, AdvocateFor Respondent: Shri Pradeep Kumar, CIT-DR
Section 133(6)Section 143(3)Section 144C

read with section 144C of the Income-tax Act, 1961 (the 'Act') pursuant to the directions issued by the Hon'ble Dispute Resolution Panel (`DRP') on the following grounds: Page 2 of 22 IT(TP)A No. 2904/Bang/2017 General 1. The order of the Id. AO and directions

Ecl Finance Ltd., Mumbai vs. A.C.I.T. - 3(1)(2), Mumbai

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

ITA 899/MUM/2018[2013-14]Status: DisposedITAT Mumbai04 Mar 2022AY 2013-14
Section 143(3)Section 144C(5)Section 92C(3)

r.w.s. 144C(13) of the Income Tax Act, (hereinafter referred to as 'the Act') in pursuance of directions of Hon'ble Dispute Resolution Panel (WZ), Mumbai (hereinafter referred to as 'the DRP') erred in assessing the total income of the assessee at Rs.2,52,39,54,290 as against ... benefit attributable solely its part of large concern and no function has been performed by EFSL. Being aggrieved, the assessee filed objection before Dispute Resolution Panel (DRP). DRP accepted the contention of the assessee that it has received the benefit of consolidated financial statement of EFSL; however, it allowed relief

DCIT 15(2)(1), Mumbai vs. Nomura Structured Finance Services P.Ltd, Mumbai

In the result, the appeal by the Revenue is dismissed in terms of our aforesaid findings

ITA 1711/MUM/2015[2010-11]Status: DisposedITAT Mumbai03 Mar 2022AY 2010-11

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Farrokh IraniFor Respondent: Smt. Vatsalya Jha
Section 143(3)Section 144C(13)Section 92C

Revenue has raised following grounds in its appeal:– "1. On the facts and in the circumstances of the case and in law, the Dispute Resolution Panel erred in deleting the addition of Rs. 7,78,15,295/- by reinstating comparable namely M/s C G Vak Software & Exports ... adjustment proposed by the TPO. M/s. Nomura Structured Finance Services Private Limited ITA No. 1711/Mum./2015 and C.O. No. 69/Mum./2015 8. The Dispute Resolution Panel („DRP‟), vide direction dated 13.11.2014 issued under section 144C(5) of the Act, inter-alia, accepting the objections filed by the assessee directed inclusion

Atos Information Technology Hk Ltd., Navi Mumbai vs. DCIT (It) - 1(1)(2), Mumbai

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

ITA 7205/MUM/2018[2011-12]Status: DisposedITAT Mumbai01 Mar 2022AY 2011-12
Section 115ASection 143(3)Section 254Section 271(1)(c)Section 9Section 9(1)(i)Section 9(1)(vi)Section 9(1)(vii)

case and in law, the Learned Deputy Commissioner of Income-tax (International Taxation) 1(1)(2), Mumbai ('the Learned AO') and the Dispute Resolution Panel ('the DRP') erred in holding the sum of Rs.40,46,45,646/- as 'Royalty' under Section 9(1)(vi) of the Income ... case and in law, the Learned Deputy Commissioner of Income-tax (International Taxation)-1(1)(2), Mumbai ('the Learned AO') and the Dispute Resolution Panel ('the DRP') erred in holding the sum of Rs.40,46,45,646 as 'Royalty' and 'Fees for Technical Services' under Section

M/S Cypress Semiconductor Technology India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-2(1)(1), Bangalore

In the result, appeal of the assessee stands partly allowed

ITA 3133/BANG/2018[2014-15]Status: DisposedITAT Bangalore28 Feb 2022AY 2014-15

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 3133/Bang/2018 Assessment Year : 2014-15 M/S. Cypress Semiconductor Technology India Pvt. Ltd., The Deputy No. 65/2, Bagmane Laurel, Commissioner Of Block C, Bagmane Tech Park, Income Tax, C.V Raman Nagar, Circle – 2 (1)(1), Bangalore – 560 093. Bangalore. Vs. Pan: Aabcc2470Q Appellant Respondent

For Respondent: Smt. Tanmayee Rajkumar
Section 133(6)Section 92CSection 92D

case and is liable to be quashed. (Tax Effect: INR 59,987,559) Page 2 IT(TP)A No. 3133/Bang/2018 2. That the Dispute Resolution Panel (learned DRP') erred in not appreciating that the order of the learned Assistant Commissioner of Income-tax (Transfer Pricing) — 1(1)(2), Bangalore (learned

Acuity Knowledge Centre (India) Private Limited (Formerly Known As Moody'S Analytics Knowledge Services (India) Private Limited), Bengaluru vs. Deputy Commissioner of Income Tax, Circle-4(1)(2), Bengaluru

In the result, appeal of the assessee is partly allowed

ITA 2689/BANG/2017[2013-14]Status: DisposedITAT Bangalore28 Feb 2022AY 2013-14

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A No.2689/Bang/2017 Assessment Year : 2013-14 Dcit, M/S. Acuity Knowledge Centre (India) Pvt. Ltd., Vs. (Formerly Known As Moody’S Analytics Knowledge Circle – 4(1)(2), Services (India)Private Limited), Bengaluru. Elixir Chancery Building, 7Th Floor, Municipal Door #135/1-2, Residency Road, Bengaluru – 560 025. Pan : Aaeca 9391 H Assessee Respondent Assessee By : Shri. Chavali Narayan, Ca Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 24.02.2022 Date Of Pronouncement : 28.02.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. Chavali Narayan, CAFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92

Adjusted Arithmetic mean 20.68% 5. Against the draft order of the AO incorporating the directions of the TPO, assessee filed objections before the Dispute Resolution Panel (DRP). The DRP excluded certain comparable companies. The assessee is aggrieved by the non-exclusion of 3 comparable companies set out in ground No.8

Red Hat India P. Ltd, Mumbai vs. Addl/Jt/Dy/Asstt/CIT/ITO, NFAC, Delhi

ITA 1379/MUM/2021[2016-17]Status: DisposedITAT Mumbai25 Feb 2022AY 2016-17

Bench: Shri Pramod Kumar & Shri Kuldip Singhassessment Year: 2016-17

For Appellant: Shri Ajit Jain, A.R. &For Respondent: Ms. Vatsala Jha, D.R
Section 143(3)Section 144B

along with the Learned Transfer Pricing Officer (‘Ld. TPO’)] under the directions of Hon’ble Dispute Resolution Panel (‘DRP’) erred on facts and in law, in determining the arm’s length price for payment of royalty and service fees under subscription segment and thereby making an adjustment ... against operating margin of the assessee at 15.24% and found its international transactions at arm’s length. 8. The Assessing Officer (AO) / Disputes Resolution Panel (DRP) made addition of Rs.28,01,90,592/- and Rs.25,97,21,357/- 11 M/s. Red Hat India Private Limited on account of unearned revenue

Timblo Shipyards P. Ltd., Mumbai vs. Assesseing Officer/ National E-Assessment Centre, Delhi

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

ITA 1168/MUM/2021[2016-17]Status: DisposedITAT Mumbai25 Feb 2022AY 2016-17

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessing Officer, National E- Timblo Shipyards Private Assessment Centre, Delhi Limited Income Tax Department, 64 Bajaj Bhavan Nariman National E-Assessment Vs. Point, Mumbai-400 021 Centre, New Delhi, Delhi-110003 (Appellant) (Respondent) Pan No. Aadct4852B Assessee By : None Revenue By : Shri Tejinder Pal Singh, Dr Date Of Hearing: 09.02.2022 Date Of Pronouncement : 25.02.2022

For Appellant: NoneFor Respondent: Shri Tejinder Pal Singh, DR
Section 143(3)Section 144C(13)Section 156

transfer pricing adjustment of ₹73,74,174/- was made. The assessee filed objection Timblo Shipyards Pvt. Ltd.; AY 16-17 before the Dispute Resolution Panel (in short DRP). However, the assessee withdrew its objection submitting that assessee would be availing benefit of ‘Vivad se Vishwas Scheme’. Therefore, Dispute Resolution Panel

M/S Te Connectivity India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle-2 Ltpu, Bangalore

In the result, the appeal by the assessee is treated as partly allowed for 37

ITA 3373/BANG/2018[2014-15]Status: DisposedITAT Bangalore25 Feb 2022AY 2014-15

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A No.3373/Bang/2018 Assessment Year : 2014-15 M/S. Te Connectivity India Private Limited, Vs. Acit, Te Park, 22B, Doddenakundi Corporation, 2Nd Circle - 2, Large Taxpayer Unit, Phase, Industrial Area, Whitefield Road, Bengaluru. Bengaluru – 560 048. Pan : Aabct 7374 C Assessee Respondent Assessee By : Shri. Sriram Seshadri, Advocate Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 22.02.2022 Date Of Pronouncement : 25.02.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. Sriram Seshadri, AdvocateFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144C

passing a final order of assessment not in that is not in conformity with the Directions of issued by the Ld. conformity Dispute Resolution Panel (“Ld. DRP”), to the extent that the relief with DRP granted by the Ld. DRP, amounting to INR 7.06 Crores, is not given Directions effect ... incorporated by the AO in the Draft Order of Assessment. The assessee filed objection to the Draft Order of Assessment before the Dispute Resolution Panel (DRP). The DRP did not accept the objections of the assessee except the following: a. On the issue of adoption of comparable companies for benchmarking

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

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

ITA 3313/BANG/2018[2014-15]Status: DisposedITAT Bangalore25 Feb 2022AY 2014-15

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiassessmentyear: 2014-15

For Appellant: Shri Nageswar Rao, A.RFor Respondent: Shri Pradeep Kumar, D.R
Section 143(3)Section 35(1)(iv)Section 40

assessing officer for assessment year 2014-15 u/s 143(3) r.w.s. 144C of the Act in pursuance of directions given by Ld Dispute Resolution Panel (DRP). 2. The grounds of appeal urged by the assessee give rise to the following issues:- (a) Addition on account of Transfer pricing adjustment

Anheuser Busch Inbev India Limited, Mumbai vs. DCIT Circle 9(1)(2), Mumbai

In the result, the appeal of the assessee in ITA

ITA 7396/MUM/2018[2014-15]Status: DisposedITAT Mumbai24 Feb 2022AY 2014-15
Section 143(3)Section 144C(1)Section 40

Income Tax Act, hereinafter referred to as Act, pursuant to the directions M/s. Anheuser Busch InBev India Limited of the ld. Dispute Resolution Panel-1 (West Zone) (DRP in short) u/s.144C(1) of the Act dated 18/09/2018 respectively for the A.Y.2014- 15. 2. The Ground Nos.2-2.1 and 3 – 3.5 raised