“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

Sabre Asia Pacific Pte. Ltd., Mumbai vs. The Asstt. CIT International Tax Circle-4(2)(1), Mumbai

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

ITA 154/MUM/2021[2017-18]Status: DisposedITAT Mumbai24 Jan 2022AY 2017-18

Bench: Shri Prashant Maharishi () & Shri Pavan Kumar Gadale () Sabre Asia Pacific Pte Ltd Vs The Assistant Commissioner Of Income-Tax 1 Paya Lebar Link, #05-05 Plq2, International Tax Circle 4(2)(1) Paya Lebar Quarter, Paya Lebar 17Th Floor, Air India Building Road, Singapore 408 533 Nariman Point Mumbai C/O Deloitte Haskins & Sells Llp One International Center Tower 3, 30Th Floor, Senapati Bapat Marg, Elphinstone (W), Mumbai- 400 013, India Pan : Aabca6590M Appellant Respondent Appellant By Shri Nitesh Joshi, Advocate Respondent By Shri Milind Chavan, Sr.Dr Date Of Hearing 07-12-2021 Date Of Pronouncement 24-01-2022 O R D E R Per Prashant Maharishi (Am)

Section 143(3)

thereon amounting to ₹ 153,448,450/–. iv. With respect to the reimbursement of expenditure the learned assessing officer followed the direction of the dispute resolution panel wherein it has been held that 10% of the reimbursement as income of the assessee is attributable to a permanent establishment in India accordingly ... issued directions on 29-10-2020 that :- a. with respect to existence of permanent establishment in India and business connection the learned dispute resolution panel followed the order of the coordinate bench in assessee’s own case for earlier years and held that as there is no change

Societe Generale Global Solution Centre Pvt Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-6(1)(2), Bengaluru

In the result, the assessee’s appeal is partly allowed

ITA 2580/BANG/2017[2013-14]Status: DisposedITAT Bangalore21 Jan 2022AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri T. Suryanarayana, Sr. CounselFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 10ASection 115JSection 143(3)Section 271Section 274

without prejudice to one another. The Appellant submits as under: 1. The Assessment Order issued by the Assessing Officer, Directions issued by the Dispute Resolution Panel and IT(TP)A No.2580/Bang/2017 Page 2 of 16 the Transfer Pricing Order issued by the Transfer Pricing Officer ... Deputy Commissioner of Income-tax, Circle 6(1)(2) (`Ld. AO'), the Ld. Dispute Resolution Panel (id. Panel') and Ld. Deputy Commissioner of Income Tax (Transfer Pricing) — 2(2)(2) (`Ld. TPO') erred on facts and in law in making an addition of INR 15,224,686 to the total

Dhr Holding India Pvt. Ltd., New Delhi vs. Addl.CIT, Special Range-3, New Delhi

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

ITA 1614/DEL/2018[2013-14]Status: DisposedITAT Delhi21 Jan 2022AY 2013-14

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

For Appellant: Shri Ajit Jain, CAFor Respondent: Shri Surender Pal, CIT DR

Section 143(3)Section 271Section 92BSection 92C

Learned Additional Commissioner of Income Tax, Special Range-3, New Delhi / Learned Assessing Officer ("Ld. AO") erred in determining, and Hon'ble Dispute Resolution Panel - I, New Delhi ("Hon'ble DRP") erred in confirming additions amounting to INR 48,47,174 to the taxable income of the Appellant on account

M/S. Target India Pvt Ltd, Bangalore vs. Joint Commissioner of Income Tax, Special Range-7, Bangalore

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

ITA 3159/BANG/2018[2014-15]Status: DisposedITAT Bangalore19 Jan 2022AY 2014-15

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.3159/Bang/2018 Assessment Year: 2014-15

For Appellant: Smt. Rashmi R., A.RFor Respondent: Shri Pradeep Kumar, D.R

CHANDRA POOJARI, ACCOUNTANT MEMBER: This appeal filed by the assessee is directed against the order of the Dispute Resolution Panel-2, Bengaluru dated 6.9.2018 for the assessment year 2014-15. 2. At the time of hearing, the Ld. A.R. requested for withdrawal of the appeal filed by the assessee

Cisco Systems Services B.V, Bangalore vs. Deputy Commissioner of Income Tax International Taxation Circle-1(1), Bangalore

In the result, the appeal by the assessee is allowed

ITA 961/BANG/2017[2012-13]Status: DisposedITAT Bangalore19 Jan 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(It)A No. 961/Bang/2017 Assessment Year : 2012-13 M/S. Cisco Systems Services B.V. – India The Deputy Branch, Commissioner Of Brigade South Parade, Income Tax, No. 10, International Taxation, Mahatma Gandhi Road, Circle – 1(1), Vs. Bangalore – 560 001. Bangalore. Pan: Aaccc4836D Appellant Respondent Assessee By : Shri Rajan Vora, Ca : Dr. Manjunath Karkaihalli, Revenue By Cit Dr Date Of Hearing : 19-01-2022 Date Of Pronouncement : 19-01-2022 Order Per Beena Pillaithis Appeal By Assessee Is Directed Against The Order Of The Ld.Ao Dated 27.02.2017 Passed U/S. 143(3) R.W.S. 144C(14) Of The Income- Tax Act, 1961 [The Act] On The Following Grounds: “Based On The Facts & Circumstances Of The Case & In Law, Cisco Systems Services B.V. - India Branch (Hereinafter Referred To As The 'Appellant.) Respectfully Craves Leave To Prefer An Appeal Against The Order Passed By The Deputy Commissioner Of Income-Tax (International Taxation) - Circle 1(1) ('Assessing Officer' Or 'Ao') Dated February 27, 2017 In Pursuance Of The Directions & The Revised Directions Issued By The Dispute Resolution Panel ('Drp'), Bangalore Dated December 29, 2016 & January 16. 2017 Respectively, Under Section 253 Of The Income-Tax Act, 1961 ('Act) On The Following Grounds:

For Appellant: Shri Rajan Vora, CA

Section 143(3)Section 253Section 92C

Taxation) - Circle 1(1) ('Assessing Officer' or 'AO') dated February 27, 2017 in pursuance of the directions & the revised directions issued by the Dispute Resolution Panel ('DRP'), Bangalore dated December 29, 2016 & January 16. 2017 respectively, under section 253 of the Income-tax Act, 1961 ('Act) on the following grounds ... such trust or institution or notification issued in respect of such trust or institution has been withdrawn or rescinded. 144C. Reference to dispute resolution panel.-- (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward a draft of the proposed order

M/S Target Corporation India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-7(1)(1), Bangalore

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

ITA 740/BANG/2017[2012-13]Status: DisposedITAT Bangalore19 Jan 2022AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.740/Bang/2017 Assessment Year: 2012-13

For Appellant: Smt. Rashmi R., A.RFor Respondent: Shri Sumer Singh Meena, D.R

CHANDRA POOJARI, ACCOUNTANT MEMBER: This appeal filed by the assessee is directed against the order of the Dispute Resolution Panel-2, Bengaluru dated 5.12.2016 for the assessment year 2014-15. 2. At the time of hearing, the Ld. A.R. requested for withdrawal of the appeal filed by the assessee

M/S Target Corporation India Pvt Ltd, Bangalore vs. Deputy Commissioner of Income Tax Circle-7(1)(1), Bangalore

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

ITA 1506/BANG/2017[2013-14]Status: DisposedITAT Bangalore19 Jan 2022AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.1506/Bang/2017 Assessment Year: 2013-14

For Appellant: Smt. Rashmi R., A.RFor Respondent: Shri Sumer Singh Meena, D.R

CHANDRA POOJARI, ACCOUNTANT MEMBER: This appeal filed by the assessee is directed against the order of the Dispute Resolution Panel-2, Bengaluru dated 20.3.2017 for the assessment year 2013-14. 2. At the time of hearing, the Ld. A.R. requested for withdrawal of the appeal filed by the assessee

Gemological Research (Thailand) Co. Ltd., Mumbai vs. The ACIT (International Taxation) Centre-2(3)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 978/MUM/2021[2017-18]Status: DisposedITAT Mumbai17 Jan 2022AY 2017-18

Section 143(3)Section 144C(5)

20/04/2021 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 16/03/2021 respectively for the A.Y.2017-18. M/s. Gemological Research (Thailand) Co. Ltd., 2. The assessee ... raised the following grounds:- 1 : 0 Re.: Holding that the Appellant has a 'Permanent Establishment' ("PE") in India:: 1 : 1 The Assessing Officer/the Dispute Resolution Panel has erred in holding that the Appellant has a 'Permanent Establishment' ("PE") in India. 1 : 2 The Appellant submits that considering the facts

Gemolagical Institute of America Inc., Mumbai vs. The ACIT (International Taxation) Circle-2(3)(2), Mumbai

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

ITA 975/MUM/2021[2017-18]Status: DisposedITAT Mumbai17 Jan 2022AY 2017-18

Section 143(3)Section 144C(5)

M/S. Cisco Systems Services B.V. India Branch, Bengaluru vs. Deputy Commissioner of Income Tax, International Taxation, Circle- 1(1), Bangalore

In the result, the appeal by the assessee is allowed

ITA 2572/BANG/2019[2011-12]Status: DisposedITAT Bangalore12 Jan 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(It)A No. 2572/Bang/2019 Assessment Year : 2011-12 M/S. Cisco Systems Services B.V. – India The Deputy Branch, Commissioner Of Brigade South Parade, Income Tax, No. 10, Mahatma Gandhi International Taxation, Road, Circle – 1(1), Vs. Bangalore – 560 001. Bangalore. Pan: Aaccc4836D Appellant Respondent Assessee By : Shri Rajan Vora, Ca Revenue By : Shri Pradeep Kumar, Cit (Dr) Date Of Hearing : 04-01-2022 Date Of Pronouncement : 12-01-2022 Order Per Beena Pillaithis Appeal By Assessee Is Directed Against The Order Of The Ld.Ao Dated 31.12.2015 Passed U/S. 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 [The Act] On The Following Grounds: “Based On The Facts & Circumstances Of The Case & In Law, Cisco Systems Services B.V. —India Branch (Hereinafter Referred To As 'The Appellant'), Respectfully Craves Leave To Prefer An Appeal Against The Order Passed By The Learned Assessing Officer (Hereinafter Referred To As The 'Learned Ao') Dated October 15, 2019 Under Section 147 Read With Section 143(3) Read With Section 144C Of The Income-Tax Act, 1961 (`The Act') Pursuant To The Directions Dated September 23, 2019 Issued By The Drp U/S 144C(5) Of The Act ('The Impugned Order') Inter-Alia On The Following Grounds:

For Appellant: Shri Rajan Vora, CAFor Respondent: Shri Pradeep Kumar, CIT (DR)

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 147Section 156Section 234BSection 271(1)(c)Section 92C(2)

such trust or institution or notification issued in respect of such trust or institution has been withdrawn or rescinded. 144C. Reference to dispute resolution panel.-- (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward a draft of the proposed order ... file his acceptance of the variations to the Assessing Officer; or (b) file his objections, if any, to such variation with, -- (i) the Dispute Resolution Panel; and (ii) the Assessing Officer. (3) The Assessing Officer shall complete the assessment on the basis of the draft order, if -- (a) the assessee

Serco India Pvt. Ltd., Gurgaon vs. DCIT, Gurgaon

In the result, the appeal of the assessee is allowed

ITA 1460/DEL/2014[2009-10]Status: DisposedITAT Delhi10 Jan 2022AY 2009-10

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 1460/Del/2014 : Asstt. Year : 2009-10 Serco India Pvt. Ltd., Vs Dcit, 6Th Floor, Tower-B, Building No. 8, Circle-2, Dlf Cyber City, Phase-Ii, Gurgaon Gurgaon (Appellant) (Respondent) Pan No. Aajcs6704P Assessee By : Sh. Suraj Bhan Nain, Ca Revenue By : Sh. M. Baranwal, Sr. Dr Date Of Hearing: 04.01.2022 Date Of Pronouncement: 10.01.2022

For Appellant: Sh. Suraj Bhan Nain, CAFor Respondent: Sh. M. Baranwal, Sr. DR

Section 10ASection 143(3)Section 144C(13)Section 234BSection 271(1)(c)Section 92C

account to the Appellant’s income. 4. That on facts and circumstances of the case and in law, The AO/ Ld. TPO/ Ld. Dispute Resolution Panel (“DRP”) erred 3 Serco India Pvt. Ltd. while making an aforesaid addition of Rs. 15,215,920 to the value of international transactions ... account of transfer pricing. 14. The assessee filed objections u/s 144C of the Act before Ld. Dispute Resolution Panel (DRP), Delhi in respect of the 8 Serco India Pvt. Ltd. addition proposed to be made by TPO. The Ld. DRP has passed order u/s 144C

M/S. Buro Happold Ltd., Mumbai vs. Dy CIT (International Taxation) -1(3)(2), Mumbai

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

ITA 951/MUM/2021[2017-18]Status: DisposedITAT Mumbai07 Jan 2022AY 2017-18

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadalem/S. Buro Happold Ltd Vs. Dcit (It) – 1(3)(2) C/O. Urmi Axis, 6Th 1810, 18Th Floor, Air Floor, Famous Studio India Bldg, Lane, Dr. Emoses Road, Narimanpoint,Mumbai- Mahalaxmi, Mumbai – 400 021. 400011. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabcb9239Q Appellant .. Respondent Appellant By : Mr.Anuj Kisnadwala. Ar Respondent By : Mr.Milind Chavan, Sr. Dr Date Of Hearing 08.12.2021 Date Of Pronouncement 10.01.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Assessment Order Passed U/S 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 In Pursuance To The Directions Of The Dispute Resolution Panel (Drp) U/Sec144C(5) Of The Act.

For Appellant: Mr.Anuj Kisnadwala. ARFor Respondent: Mr.Milind Chavan, Sr. DR

Section 143(2)Section 143(3)Section 144C(1)Section 234B

Assessment order passed u/s 143(3) r.w.s 144C(13) of the Income Tax Act, 1961 in pursuance to the directions of the Dispute Resolution Panel (DRP) U/sec144C(5) of the Act. The assessee has raised the following grounds of appeal: 1. Ground No. I - Taxability of amount received for Consulting ... Buro Happold Ltd, Mumbai. services (FTS) 1.1 On the facts and in the circumstances of the case and in law, the learned DRP ('Dispute Resolution Panel') and DCIT have erred in considering income from consulting and engineering services amounting to INR 4,20,666/- as Fees for technical services

Nomura Services India P. Ltd, Mumbai vs. DCIT 10(3), Mumbai

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

ITA 2303/MUM/2013[2008-09]Status: DisposedITAT Mumbai06 Jan 2022AY 2008-09

Bench: Shri Pramod Kumar & Shri Pavan Kumar Gadalenomura Services India Vs. Dcit – Circle 10(3) Pvt Ltd., Aayakar Bhavan, 10Th Floor, Nomura, Mk Road, Off High Street, Mumbai – 400020. Hiranandani Business Park, Powai, Mumbai – 400076. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabcl0053C Appellant .. Respondent Appellant By : Mr.Faruk Irani & Mr Sumin Mehta.Ar Respondent By : Mrs.Vatsala Jha. Dr Date Of Hearing 23.11.2021 Date Of Pronouncement 10.01.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Passed U/S 143(3) R.W.S 144C(13) Of The Act In Pursuance To Directions Of The Dispute Resolution Panel (Drp) U/Sec144C(5) Of The Act Dated 07.09.2012. Nomura Services India P Ltd., Mumbai. 2. The Assessee Has Filed The Fallowing Grounds Of Appeal As Under:

For Appellant: Mr.Faruk Irani &For Respondent: Mrs.Vatsala Jha. DR

Section 143(3)

filed the appeal against the order passed u/s 143(3) r.w.s 144C(13) of the Act in pursuance to directions of the Dispute Resolution Panel (DRP) u/sec144C(5) of the Act dated 07.09.2012. Nomura Services India P Ltd., Mumbai. 2. The assessee has filed the fallowing grounds of appeal ... dated 19.12.2011.Wheras, the assessee has filed the objections in Form no 35A against the draft assessment order with the Dispute Resolution Panel Nomura Services India P Ltd., Mumbai. (DRP).Whereas the DRP after considering the objections and the findings of the TPO has issued directions in respect of comparables

Expeditors International of Washinton, Usa, Washington vs. ACIT, Circle-1(2)(2) Int.Tax., New Delhi

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

ITA 180/DEL/2021[2017-18]Status: DisposedITAT Delhi05 Jan 2022AY 2017-18

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 144C(13)Section 234BSection 234CSection 271Section 9Section 9(1)(vii)

Officer ("Ld. AO") is erroneous and bad in law as well as in facts. 2. That the Ld. AO and the Hon'ble Dispute Resolution Panel ('Hon'ble DRP') on the facts and law, have erred in holding that fee for freight/ logistic support services by the T"1 Appellant ... total income at Rs. 3,12,41,26,601/-. 4. The assessee aggrieved by the proposed order filed its objection before the Dispute Resolution Panel-1, New Delhi [in short “the DRP-1”]. The objections of the assessee for decided against the assessee. Therefore, the Assessing Officer in pursuance

Expeditors International of Washington Inc., Usa vs. ACIT (International Taxation), New Delhi

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

ITA 1904/DEL/2017[2012-13]Status: DisposedITAT Delhi05 Jan 2022AY 2012-13

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 144C(13)Section 234BSection 234CSection 271Section 9Section 9(1)(vii)

M/S. Randox Laboratories India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle- 5(1)(1), Bangalore

In the result, appeal by the Assessee is partly allowed for statistical purpose

ITA 2576/BANG/2019[2015-16]Status: DisposedITAT Bangalore04 Jan 2022AY 2015-16

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A No.2576/Bang/2019 Assessment Year : 2015-16 M/S. Randox Laboratories India Vs. The Asst.Commissioner Of Private Limited, Income Tax, Plot No.191-195 & 246-250, Circle 5(1)(1), Bommasandra-Jigani Link Road, Bengaluru. Kiadb Industrial Area, Bengaluru – 560 105. Pan: Aadcr 0074 K Assessee Respondent

For Appellant: Shri S. Krishna Upadhyaya, CAFor Respondent: Shri Sumeer Singh Meena, CIT(DR-OSD), ITAT, Bangalore

Section 143(3)Section 144CSection 92Section 92ASection 92CSection 92F

objection to the draft assessment order in which the addition proposed by the TPO was added to the total income, before the Dispute Resolution Panel (DR) contended that the Assessee is merely a distributor and the activity conducted by the Assessee is that of buying and reselling reagents and analysers

Textron India Private Limited, Bangalore vs. DCIT, Bangalore

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

ITA 678/BANG/2016[2011-12]Status: DisposedITAT Bangalore04 Jan 2022AY 2011-12

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.678/Bang/2016 Assessment Year: 2011-12

For Appellant: Shri Sumeeth Khurana, A.RFor Respondent: Shri Sumer Singh Meena, D.R (OSD)

Section 10ASection 143(3)Section 40

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 (DRP). 2. The appeal filed by the assessee give rise to the following issues:- (a) Transfer pricing adjustment made in respect of “Engineering Design Segment”. (b) Transfer

DCIT, Bangalore vs. M/S Textron India Pvt. Ltd., Bangalore

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

ITA 594/BANG/2016[2011-12]Status: DisposedITAT Bangalore04 Jan 2022AY 2011-12

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.678/Bang/2016 Assessment Year: 2011-12

For Appellant: Shri Sumeeth Khurana, A.RFor Respondent: Shri Sumer Singh Meena, D.R (OSD)

Section 10ASection 143(3)Section 40

M/S Euronet Services India Pvt Lt D, Bangalore vs. Deputy Commissioner of Income Tax Circle-2(1)(2), Bangalore

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

ITA 329/BANG/2017[2012-13]Status: DisposedITAT Bangalore27 Dec 2021AY 2012-13

Bench: Shri George George K. & Shri B.R. Baskaranit(Tp)A No.329/Bang/2017 Assessment Year : 2012-13

For Appellant: Shri K.R. Vasudevan, A.RFor Respondent: Shri Sanjay Kumar, D.R

Section 10ASection 143(3)

Income-tax Act,1961 ['the Act' for short] for assessment year 2012-13 in pursuance of directions issued by Ld. Dispute Resolution Panel (DRP). The grounds urged by the assessee relate to the following two issues:- a) Transfer pricing adjustment made in respect of payment of Corporate management services

Cisco Systems Services B V India Branch, Bengaluru vs. Deputy Commissioner of Income Tax, International Taxation, Circle-1(1), Bengaluru

In the result, the appeal by the assessee is allowed

ITA 2888/BANG/2017[2013-14]Status: DisposedITAT Bangalore27 Dec 2021AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Rajan Vora, CAFor Respondent: Shri Sumer Singh Meena, CIT(DR)(OSD)

Section 143(3)

2888/Bang/2017 Page 10 of 22 notification issued in respect of such trust or institution has been withdrawn or rescinded. 144C. Reference to dispute resolution panel.— (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward a draft of the proposed order ... file his acceptance of the variations to the Assessing Officer; or (b) file his objections, if any, to such variation with, -- (i) the Dispute Resolution Panel; and (ii) the Assessing Officer. (3) The Assessing Officer shall complete the assessment on the basis of the draft order, if -- (a) the assessee