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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

Kellogg India P.Ltd, Mumbai vs. Assistant Commissioner of Income Tax 15(2)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 7342/MUM/2018[2014-15]Status: DisposedITAT Mumbai16 Feb 2022AY 2014-15
Section 143(3)Section 144C(5)Section 92C

29/10/2018 u/s.143(3) r.w.s. 144C(13) of the Income Tax Act, 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 12/09/2018 respectively for the A.Y.2014-15. 2 M/s. Kellogg India Private Limited 2. The Ground

Kennametal Inc, Bangalore vs. Assistant Commissioner of Income Tax (International Taxation), Circle-1(2), Bangalore

In the result, the appeal for AY 2014-15 is treated as allowed for statistical purpose while the appeal for AY 2012-13

ITA 35/BANG/2021[2017-18]Status: DisposedITAT Bangalore16 Feb 2022AY 2017-18

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranit(It)A No.35/Bang/2021 Assessment Year :2017-18 M/S. Kennametal Inc., Vs. Acit (International Taxation), C/O. Kennametal India, Circle – 1(2), 8/9Th Mile, Tumkur Road, Bengaluru. Bengaluru – 560 073. Pan: Aacck 6397 B Assessee Respondent Assessee By : Shri. K. R. Vasudevan, Advocate Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 14.02.2022 Date Of Pronouncement : 16.02.2022 O R D E R Per N. V. Vasudevan:

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 9(1)(vi)

No.35/Bang/2021 Page 2 of 9 3. The factual circumstances under which the aforesaid addition was made by the AO and confirmed by the Dispute Resolution Panel (DRP) are that the assessee is a foreign assessee incorporated under the laws of Commonwealth of Pennsylvania, USA and is engaged in the business

Bateman Engineering (India) Private Limited, Bangalore vs. DCIT, Bangalore

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

ITA 749/BANG/2016[2011-12]Status: DisposedITAT Bangalore15 Feb 2022AY 2011-12

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.469/Bang/2016 Assessmentyear: 2011-12

For Appellant: Shri Nageswar Rao, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 143(3)

r.w.s. 144C(13) of the Income-tax Act,1961 ['the Act' for short] in pursuance of directions given by Ld. Dispute Resolution Panel (“Ld. DRP”). 2. At the time of hearing, the Ld. A.R. pressed only ground No.6 relating to working capital adjustment and ground No.10 relating to two comparable ... Company Ltd as a comparable company in the final set of comparable companies, due to inadvertent error in directions of the Hon’ble Dispute Resolution Panel.” 3. The facts relating to the case are stated in brief. The assessee is a subsidiary of Bateman Engineering N.V., Netherlands

DCIT, Bangalore vs. M/S Bateman Engineering India Pvt. Ltd., Bangalore

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

ITA 469/BANG/2016[2011-12]Status: DisposedITAT Bangalore15 Feb 2022AY 2011-12

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.469/Bang/2016 Assessmentyear: 2011-12

For Appellant: Shri Nageswar Rao, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 143(3)

r.w.s. 144C(13) of the Income-tax Act,1961 ['the Act' for short] in pursuance of directions given by Ld. Dispute Resolution Panel (“Ld. DRP”). 2. At the time of hearing, the Ld. A.R. pressed only ground No.6 relating to working capital adjustment and ground No.10 relating to two comparable ... Company Ltd as a comparable company in the final set of comparable companies, due to inadvertent error in directions of the Hon’ble Dispute Resolution Panel.” 3. The facts relating to the case are stated in brief. The assessee is a subsidiary of Bateman Engineering N.V., Netherlands

Ibm India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

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

ITA 289/BANG/2021[2015-16]Status: DisposedITAT Bangalore14 Feb 2022AY 2015-16

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiit(Tp)A No. 289/Bang/2021 Assessment Year : 2015-16 M/S. Ibm India Pvt. Ltd., The Deputy No. 12, Subramanya Commissioner Of Arcade, Income-Tax, Bannerghatta Road, Circle 3 (1)(1), Bangalore – 560 029. Vs. Bangalore. Pan: Aaaci4403L Appellant Respondent Assessee By : Shri Ajay Roti, Ca Revenue By : Shri Pradeep Kumar, Cit Dr Date Of Hearing : 12-01-2022 Date Of Pronouncement : 14-02-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Final Assessment Order Dated 30.04.2021 U/S. 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Act Passed By The National Faceless Assessment Centre, Delhi Relating To Assessment Year 2015-16 On Following Grounds Of Appeal: “The Grounds Stated Hereunder Are Independent Of & Without Prejudice To One Another. The Appellant Submits As Under: 1. Assessment Order Bad In Law 1.1. At The Outset, M/S Ibm India Private Limited (Hereinafter Referred To As 'The Appellant' Or 'The Company') Prays That The Order Dated April 30. 2021

For Appellant: Shri Ajay Roti, CAFor Respondent: Shri Pradeep Kumar, CIT DR
Section 10ASection 143(3)Section 144BSection 144C(13)

Assessment Centre ('the NeAC'), be struck down as invalid, as the order is bad in law and on facts. 1.2. The Hon'ble Dispute Resolution Panel ('ORP') has erred in completing the proceedings in undue haste and in violation of the principles of natural justice by not affording an opportunity

Bharat Vijaykumar Jain (HUF), Bangalore vs. Deputy Commissioner of Income Tax, Central Circle- 2(2), Bangalore

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

ITA 246/BANG/2021[2016-17]Status: DisposedITAT Bangalore14 Feb 2022AY 2016-17

Bench: Shri George George K & Ms. Padmavathy S

For Appellant: Shri Narendra Kumar Jain, AdvocateFor Respondent: Shri Muzaffar Hussain, CIT(DR)
Section 139(1)Section 143(2)Section 143(3)Section 234BSection 92C

16/10/2019 determined the adjustment u/s 92CA for an amount of Rs.66,54,892/-. Aggrieved by the adjustments made, assessee filed adjustments before the Dispute Resolution Panel (DRP). The DRP, vide its direction dated 29/3/2021 disposed of the objections of the assessee. Pursuant to the DRP’s directions the final assessment

M/S Toyota Kirloskar Auto Parts Pvt Ltd, Bangalore vs. Assistant Commissioner of Income Tax Ltu Circle-1, Bangalore

In the result, the appeal in IT(TP)A No

ITA 1364/BANG/2017[2012-13]Status: DisposedITAT Bangalore10 Feb 2022AY 2012-13

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.1714/Bang/2016 : Asst.Year 2012-2013 It(Tp)A No.1364/Bang/2017 : Asst.Year 2012-2013 M/S.Toyota Kirloskar Auto Parts The Assistant Commissioner Private Limited Of Income-Tax, Ltu, Circle-1 V. Plot No.21, Bidadi Industrial Area Bangalore. Bidadi, Ramangara District – 562 109. Pan : Aabct5590Q. (Appellant) (Respondent) Appellant By : Sri.K.R.Vasudevan, Advocate Respondent By : Sri.Muzaffar Hussain, Cit-Dr Date Of Pronouncement : 10.02.2022 Date Of Hearing : 09.02.2022 O R D E R Per George George K, Jm : These Appeals At The Instance Of The Assessee Are Directed Against Two Orders Of The Assessing Officer. The It(T)A No.1714/Bang/2016 Arises Out Of A.O’S Order Passed U/S 143(3) R.W.S. 144C Of The I.T.Act, (Order Dated 29.07.2016). The It(Tp)A No.1364/Bang/2017 Arises Out Of The A.O.’S Order Passed U/S 154 (Order Dated 31.01.2011). The A.O. After Passing The Order U/S 143(3) Of The Act, Passed Rectification Order U/S 154 Of The Act Giving Effect To The Order Passed By The Transfer Pricing Officer (Tpo) In Determining The Transfer Pricing (Tp) Adjustment From Rs.37,24,00,000, To Rs.39,13,10,000, Hence Two Appeals Are Filed By The Assessee. The Relevant Assessment Year Is 2012-2013. 2 It(Tp)A Nos.1714/B/2016 & 1364/Bang/2017 M/S.Toyota Kirloskar Auto Parts Private Limited. 2. The Grounds Raised For Both The Appeals Are Identical. The Assessee Has Also Filed Additional Ground Vide Letter Dated 27.11.2021.The Additional Grounds Are Essentially, Shades Of Grounds Raised In Form No.36. The Additional Grounds Are Legal Grounds Supported By Judicial Pronouncements & Does Not Require Examination Of New Facts Other Than On Record. Hence, The Additional Grounds Raised Are Taken On Record For Adjudication. We Shall First Adjudicate It(Tp)A No.1714/Bang/2016 Arising Out Of The Order Of The A.O. Passed U/S 143(3) R.W.S. 144C Of The I.T.Act.

For Appellant: Sri.K.R.Vasudevan, AdvocateFor Respondent: Sri.Muzaffar Hussain, CIT-DR
Section 143(2)Section 143(3)Section 154Section 234BSection 92C

also observed that this amount includes adjustment on account of royalty amounting to Rs.22,82,57,924. The assessee filed objections before the Dispute Resolution Panel (DRP). The DRP vide its directions dated 20.06.2016 disposed of the objections of the assessee. The objections of the 3 IT(TP)A Nos.1714/B/2016

M/S.Toyota Kirloskar Auto Parts Pvt. Ltd., Ramanagar vs. Assistant Commissioner of Income-Tax, Bangalore

In the result, the appeal in IT(TP)A No

ITA 1714/BANG/2016[2012-13]Status: DisposedITAT Bangalore10 Feb 2022AY 2012-13

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.1714/Bang/2016 : Asst.Year 2012-2013 It(Tp)A No.1364/Bang/2017 : Asst.Year 2012-2013 M/S.Toyota Kirloskar Auto Parts The Assistant Commissioner Private Limited Of Income-Tax, Ltu, Circle-1 V. Plot No.21, Bidadi Industrial Area Bangalore. Bidadi, Ramangara District – 562 109. Pan : Aabct5590Q. (Appellant) (Respondent) Appellant By : Sri.K.R.Vasudevan, Advocate Respondent By : Sri.Muzaffar Hussain, Cit-Dr Date Of Pronouncement : 10.02.2022 Date Of Hearing : 09.02.2022 O R D E R Per George George K, Jm : These Appeals At The Instance Of The Assessee Are Directed Against Two Orders Of The Assessing Officer. The It(T)A No.1714/Bang/2016 Arises Out Of A.O’S Order Passed U/S 143(3) R.W.S. 144C Of The I.T.Act, (Order Dated 29.07.2016). The It(Tp)A No.1364/Bang/2017 Arises Out Of The A.O.’S Order Passed U/S 154 (Order Dated 31.01.2011). The A.O. After Passing The Order U/S 143(3) Of The Act, Passed Rectification Order U/S 154 Of The Act Giving Effect To The Order Passed By The Transfer Pricing Officer (Tpo) In Determining The Transfer Pricing (Tp) Adjustment From Rs.37,24,00,000, To Rs.39,13,10,000, Hence Two Appeals Are Filed By The Assessee. The Relevant Assessment Year Is 2012-2013. 2 It(Tp)A Nos.1714/B/2016 & 1364/Bang/2017 M/S.Toyota Kirloskar Auto Parts Private Limited. 2. The Grounds Raised For Both The Appeals Are Identical. The Assessee Has Also Filed Additional Ground Vide Letter Dated 27.11.2021.The Additional Grounds Are Essentially, Shades Of Grounds Raised In Form No.36. The Additional Grounds Are Legal Grounds Supported By Judicial Pronouncements & Does Not Require Examination Of New Facts Other Than On Record. Hence, The Additional Grounds Raised Are Taken On Record For Adjudication. We Shall First Adjudicate It(Tp)A No.1714/Bang/2016 Arising Out Of The Order Of The A.O. Passed U/S 143(3) R.W.S. 144C Of The I.T.Act.

For Appellant: Sri.K.R.Vasudevan, AdvocateFor Respondent: Sri.Muzaffar Hussain, CIT-DR
Section 143(2)Section 143(3)Section 154Section 234BSection 92C

also observed that this amount includes adjustment on account of royalty amounting to Rs.22,82,57,924. The assessee filed objections before the Dispute Resolution Panel (DRP). The DRP vide its directions dated 20.06.2016 disposed of the objections of the assessee. The objections of the 3 IT(TP)A Nos.1714/B/2016

De Daimond Electric India Pvt. Ltd., Rewari vs. Jt.CIT, New Delhi

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

ITA 600/DEL/2017[2012-13]Status: DisposedITAT Delhi10 Feb 2022AY 2012-13

Bench: Shri Rama Kanta Panda & Shri Challa Nagendra Prasadआयकर अपील सं./I.T.A. No.600/Del/2017) ("नधा"रण वष" / Assessment Year: 2012-13)

For Appellant: Gravit Gosain, AdvFor Respondent: 29.11.2021
Section 144C(5)Section 92CSection 92C(2)

Pronouncement आदेश/O R D E R PER C.N. PRASAD - JM: This appeal is filed by the assessee against the order of the Dispute Resolution Panel passed u/s 144C(5) of the I.T. Act. The assessee raised ground nos. 4.6, 4.7 and 5 in respect of depreciation adjustment which

M/S. Tejas Networks Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Ltu, Circle-1, Bengaluru

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 582/BANG/2021[2010-11]Status: DisposedITAT Bangalore09 Feb 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

days in filing the present appeal against the order of the learned Assessing officer giving effect to the directions of the learned Dispute Resolution Panel IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 5 of 34 under section ... learned AO"), learned Additional Commissioner of Income Tax (Transfer Pricing — III), Bangalore ("Transfer Pricing Officer" or the "learned TPO") and the Hon'ble Dispute Resolution Panel ("DRP") have erred in determining the Arm's Length Price (`ALP') of the following international transactions of the Appellant: • Interest on loan advanced; • Interest

M/S Tejats Networks Limited, Bangalore vs. Principal Commissioner of Income Tax Central, Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 1674/BANG/2018[2011-12]Status: DisposedITAT Bangalore09 Feb 2022AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

days in filing the present appeal against the order of the learned Assessing officer giving effect to the directions of the learned Dispute Resolution Panel IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 5 of 34 under section ... learned AO"), learned Additional Commissioner of Income Tax (Transfer Pricing — III), Bangalore ("Transfer Pricing Officer" or the "learned TPO") and the Hon'ble Dispute Resolution Panel ("DRP") have erred in determining the Arm's Length Price (`ALP') of the following international transactions of the Appellant: • Interest on loan advanced; • Interest

Tejas Networks Limited, Bangalore vs. DCIT, Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 694/BANG/2016[2011-12]Status: DisposedITAT Bangalore09 Feb 2022AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

days in filing the present appeal against the order of the learned Assessing officer giving effect to the directions of the learned Dispute Resolution Panel IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 5 of 34 under section ... learned AO"), learned Additional Commissioner of Income Tax (Transfer Pricing — III), Bangalore ("Transfer Pricing Officer" or the "learned TPO") and the Hon'ble Dispute Resolution Panel ("DRP") have erred in determining the Arm's Length Price (`ALP') of the following international transactions of the Appellant: • Interest on loan advanced; • Interest

DCIT, Bangalore vs. M/S Tejas Networks Limited, Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 621/BANG/2016[2011-12]Status: DisposedITAT Bangalore09 Feb 2022AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

days in filing the present appeal against the order of the learned Assessing officer giving effect to the directions of the learned Dispute Resolution Panel IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 5 of 34 under section ... learned AO"), learned Additional Commissioner of Income Tax (Transfer Pricing — III), Bangalore ("Transfer Pricing Officer" or the "learned TPO") and the Hon'ble Dispute Resolution Panel ("DRP") have erred in determining the Arm's Length Price (`ALP') of the following international transactions of the Appellant: • Interest on loan advanced; • Interest

Tejas Networks Limited, Bangalore vs. Asst.C.I.T., Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 468/BANG/2015[2010-11]Status: DisposedITAT Bangalore09 Feb 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

days in filing the present appeal against the order of the learned Assessing officer giving effect to the directions of the learned Dispute Resolution Panel IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 5 of 34 under section ... learned AO"), learned Additional Commissioner of Income Tax (Transfer Pricing — III), Bangalore ("Transfer Pricing Officer" or the "learned TPO") and the Hon'ble Dispute Resolution Panel ("DRP") have erred in determining the Arm's Length Price (`ALP') of the following international transactions of the Appellant: • Interest on loan advanced; • Interest

Asst.C.I.T., Bangalore vs. M/S Tejas Networks Limited, Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 296/BANG/2015[2010-11]Status: DisposedITAT Bangalore09 Feb 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

days in filing the present appeal against the order of the learned Assessing officer giving effect to the directions of the learned Dispute Resolution Panel IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 5 of 34 under section ... learned AO"), learned Additional Commissioner of Income Tax (Transfer Pricing — III), Bangalore ("Transfer Pricing Officer" or the "learned TPO") and the Hon'ble Dispute Resolution Panel ("DRP") have erred in determining the Arm's Length Price (`ALP') of the following international transactions of the Appellant: • Interest on loan advanced; • Interest

DCIT, Bangalore vs. M/S Tejas Networks Limited, Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 1119/BANG/2015[2010-11]Status: DisposedITAT Bangalore09 Feb 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

days in filing the present appeal against the order of the learned Assessing officer giving effect to the directions of the learned Dispute Resolution Panel IT(TP)A No.296, 468 & 1119/Bang/2015 IT(TP)A No.621 & 694/Bang/2016, IT(TP)A No.1674/Bang/2018 & IT(TP)A No.582/Bang/2021 Page 5 of 34 under section ... learned AO"), learned Additional Commissioner of Income Tax (Transfer Pricing — III), Bangalore ("Transfer Pricing Officer" or the "learned TPO") and the Hon'ble Dispute Resolution Panel ("DRP") have erred in determining the Arm's Length Price (`ALP') of the following international transactions of the Appellant: • Interest on loan advanced; • Interest

Neogenetics Foods Private Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

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

ITA 361/BANG/2021[2016-17]Status: DisposedITAT Bangalore07 Feb 2022AY 2016-17

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A No.361/Bang/2021 Assessment Year : 2016-17 M/S. Neogenetics Foods Private Limited, Vs. Dcit, Level 14 & 15, Concorde Towers, Ub City, 1 Circle - 3(1)(1), Vittal Malya Road, Ub City, Bengaluru. Bengaluru – 560 001. Pan : Aadcn 7689 L Assessee Respondent Assessee By : Shri. Narendra Kumar Jain, Advocate Revenue By : Dr. Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 03.02.2022 Date Of Pronouncement : 07.02.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. Narendra Kumar Jain, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 144CSection 92BSection 92C

determined as TP Adjustment. A Draft Order of assessment was passed incorporating the TP adjustment. The assessee filed objections before Dispute Resolution Panel (DRP) under section 144C of the Act. IT(TP)A No.361/Bang/2021 Page 4 of 15 6. In its directions dated 30.3.021, the DRP directed as follows: Directions

Harman Connected Services Corporation India Private Limited (Formerly Known As M/S Core Objects India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(1)(2), Bangalore

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

ITA 682/BANG/2016[2011-12]Status: DisposedITAT Bangalore07 Feb 2022AY 2011-12

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaran

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92C

depreciation on computer software claimed by the assessee, for non deduction of tax at source. Aggrieved, the assessee filed its objections before the Dispute Resolution Panel (DRP), which, vide its directions dated 28.12.2015 granted marginal relief to the assessee in respect of the TP adjustment, while deleting the proposal ... incorporated by the AO in the Draft Order of Assessment. The assessee filed objections against the Draft Order of Assessment before the Dispute Resolution Panel (DRP). Briefly, the directions issued by the DRP were as follows: (a) The following companies were directed to be excluded by accepting the contentions

Lg Electronics Inc., Korea (Lgek), Noida vs. DCIT, Circle- 2(2)(1), International Taxation, New Delhi

In the result, the appeals of the assessee in:

ITA 5022/DEL/2018[2014-15]Status: DisposedITAT Delhi07 Feb 2022AY 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Ms. Anupama Anand, CIT- DR
Section 144C(13)Section 147Section 234ASection 263Section 271(1)(c)

Respondent-Assessee with its AE; (Hi) the TPO determined upward adjustment of Rs. 56,30,78,638/-; (iv) the Respondent- Assessee approached Dispute Resolution Panel (DRP). which declined to interfere with the transfer pricing adjustment made by the AO; (v) the Respondent- Assessee thereafter approached the 1TAT and the ITAT

Lg Electronics Inc., Korea (Lgek), Noida vs. DCIT, Circle- 2(2)(1), International Taxation, New Delhi

In the result, the appeals of the assessee in:

ITA 5021/DEL/2018[2010-11]Status: DisposedITAT Delhi07 Feb 2022AY 2010-11

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Ms. Anupama Anand, CIT- DR
Section 144C(13)Section 147Section 234ASection 263Section 271(1)(c)

Respondent-Assessee with its AE; (Hi) the TPO determined upward adjustment of Rs. 56,30,78,638/-; (iv) the Respondent- Assessee approached Dispute Resolution Panel (DRP). which declined to interfere with the transfer pricing adjustment made by the AO; (v) the Respondent- Assessee thereafter approached the 1TAT and the ITAT