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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. Finastra Software Solutions (India) Private Limited, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-4(1)(2), Bengaluru

In the result, appeal of the assessee is partly allowed

ITA 2695/BANG/2017[2013-14]Status: DisposedITAT Bangalore21 Dec 2021AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.2695/Bang/2017 Assessment Year : 2013-14 M/S. Finastra Software Solutions (India) Vs. The Acit, Private Limited, Circle - 4(1)(2), [Formerly Known As Misys Software Solutions Bengaluru. (India) Pvt. Ltd.,], 4Th To 6Th Floor, North Tower, Virgo Building, Bagmane Constellation, Bengaluru – 500 037. Pan : Aaack 9067 G Assessee Respondent Assessee By : Shri. T. Suryanarayana, Advocate Respondent By : Shri. Arunkumar, Cit(Tp-2)(Dr)(Itat), Bengaluru Date Of Hearing : 16.12.2021 Date Of Pronouncement : 21.12.2021 O R D E R Per N. V. Vasudevan: This Is An Appeal By The Assessee Against The Final Order Of Assessment Dated 06.10.2017 Of Acit, Circle – 4(1)(2), Bengaluru, Passed Under Section 143(3) R.W.S. 144C(B) Of The Income Tax Act, 1961 (Act) In Relation To Ay 2013-2014. 2. The Issue That Arises For Consideration In The Above Appeal Pertains To The Aggregate Transfer Pricing Adjustment (“Tp Adjustment”) Of Rs.14,33,66,140/- Made By The Transfer Pricing Officer (‘The Tpo’ For Short) Towards The International Transactions Of Provision Of Software Development Services (Rs.13,56,24,957/-) & Information Technology Enabled Services

For Appellant: Shri. T. Suryanarayana, AdvocateFor Respondent: Shri. Arunkumar, CIT(TP-2)(DR)(ITAT), Bengaluru
Section 143(3)Section 92

assessee’s Associated Enterprises, which was subsequently reworked to Rs.15,49,23,283/- on giving effect to the directions of the Dispute Resolution Panel (‘the DRP’ for short). 3. The assessee is a wholly owned subsidiary of Misys India Holding Ltd., UK which is a part of the Misys Group ... addition of Rs.13,56,24,957/- to the total income of the assessee being shortfall in ALP, the assessee performed objections before the Dispute Resolution Panel (DRP). Briefly, the directions issued by the DRP are as follows: IT(TP)A No.2695/Bang/2017 Page 5 of 20 Functional comparability:  Upon accepting

Nokia India Pvt. Ltd., Gurgaon vs. Addl.CIT, Special Range-6, New Delhi

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

ITA 6502/DEL/2017[2013-14]Status: DisposedITAT Delhi16 Dec 2021AY 2013-14

Bench: Shri R.K.Panda & Shri Kul Bharat

Section 143(3)Section 144CSection 40Section 928Section 92C(1)

Assessing Officer passed a draft assessment order dated 27.12.2016 against which the assessee had filed its objections before the Dispute Resolution Panel (“DRP”) who after considering the objections of the assessee revised transfer pricing adjustment amounting to Rs. 46,47,41,570/-. The Assessing Officer therefore, made adjustment

San Disk India Device Design Centre Pvt. Ltd., Bangalore vs. ITO, Bangalore

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

ITA 543/BANG/2015[2010-11]Status: DisposedITAT Bangalore15 Dec 2021AY 2010-11

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

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Shri. Sunil Kumar Singh, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(3)Section 154Section 92C

adjustment and thus arrived at the WC-adjusted mean margin of 20.73%. 11. The assessee filed objections before the Dispute Resolution Panel (DRP) against the proposed additions. Briefly, the directions issued by the DRP are as under: (i) Limitation: The Assessee's contention that the assessment order is barred ... services segment and these grounds read as follows: 2. On the facts and in the circumstances of the case the Dispute Resolution Panel erred in law in holding that the size, turnover and brand of the company are the deciding factors for treating a company as a comparable and accordingly

DCIT, Bangalore vs. M/S Sandisk India Device Design Centre Private Limited, Bangalore

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

ITA 341/BANG/2015[2010-11]Status: DisposedITAT Bangalore15 Dec 2021AY 2010-11

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

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Shri. Sunil Kumar Singh, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(3)Section 154Section 92C

adjustment and thus arrived at the WC-adjusted mean margin of 20.73%. 11. The assessee filed objections before the Dispute Resolution Panel (DRP) against the proposed additions. Briefly, the directions issued by the DRP are as under: (i) Limitation: The Assessee's contention that the assessment order is barred ... services segment and these grounds read as follows: 2. On the facts and in the circumstances of the case the Dispute Resolution Panel erred in law in holding that the size, turnover and brand of the company are the deciding factors for treating a company as a comparable and accordingly

Srf Limited, New Delhi vs. ACIT, Circle- 1, Ltu, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 6620/DEL/2018[2014-15]Status: DisposedITAT Delhi13 Dec 2021AY 2014-15

Bench: Sh. Anil Chaturvedi & Shri Kuldip Singh(Through Video Conferencing) Srf Limited Vs. Acit The Galleria, Dlf Mayur Circle – 1, Vihar, Unit No.236 & 237, Ltu 2Nd Floor, Mayur Place, New Delhi Noida Link Road, Mayur Vihar, Phase-I, Extension, Delhi-110 091 Pan : Aaacs 0206 P (Appellant) (Respondent) Assessee By Shri Pradeep Dinodia, C.A. Revenue By Ms. Meera Srivastava, Cit-D.R. Date Of Hearing: 16.09.2021 Date Of Pronouncement: 13.12.2021 Order Per Anil Chaturvedi, Am :

Section 115JSection 143(2)Section 143(3)Section 144C(5)Section 92C

Asstt. Commissioner of Income Tax, Circle-1, LTU, New Delhi passed under section 144C(5) of the Act pursuant to the directions of Dispute Resolution Panel (DRP) – 2, for Assessment Year 2014-15. 2 2. The relevant facts as culled from the material on records are as under : 3. Assessee

Intelsat Corporation, New Delhi vs. DCIT, Circle- 2(1)(1), International Taxation, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 4946/DEL/2017[2014-15]Status: DisposedITAT Delhi13 Dec 2021AY 2014-15

Bench: Shri N.K. Billaiya & Shri Challa Nagendra Prasad

For Appellant: Shri Vishal Kalra, AdvFor Respondent: Smt Anupama Anand, CIT-DR
Section 144C(13)Section 271Section 9

subject year. 1.1. That on the facts and in the circumstances of the case and in law, the Hon’ble Dispute Resolution Panel (“Hon'ble Panel”) erred in not directing the Ld. AO to hold that the appellant is not liable to tax in India. 2. That on the facts

Astro Offshore Pte. Ltd., Singapore vs. DCIT, Int. Tax. Circle-1(1)(1), New Delhi

In the result, the appeal is allowed as indicated above

ITA 192/DEL/2021[2012-13]Status: DisposedITAT Delhi09 Dec 2021AY 2012-13

Bench: Shri Saktijit Dey, Judcial Member & Dr. B.R.R. Kumarassessment Year: 2012-13

Section 144C(1)Section 144C(2)Section 144C(2)(b)Section 144C(4)Section 144C(4)(b)Section 147Section 148

total income of the assessee at Rs.45,17,870/-. 4. Against the draft assessment order so passed, the assessee raised objections before learned Dispute Resolution Panel (DRP)- 1, New Delhi, on 27.01.2020. While dealing with the objections of the assessee, learned DRP noticed that the draft assessment order was served ... look into some of the provisions of Section 144C of the Act, relevant for our purpose. They are as under: “Reference to dispute resolution panel. 144C. (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward a draft of the proposed

Turner Broadcasting System Asia Pacific Inc., New Delhi vs. DCIT (International Taxation), Circle-3(1)(1), New Delhi

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

ITA 4325/DEL/2018[2014-15]Status: DisposedITAT Delhi08 Dec 2021AY 2014-15

Bench: Sh. N. K. Billaiya & Sh. C. N. Prasad(Through Video Conferencing) Assessment Year: 2014-15 Turner Broadcasting Dcit (International System Asia Pacific Inc. Vs Taxation), Circle – 3 (1) (1) C/O Pricewaterhouse New Delhi Coopers Pvt. Ltd. Sucheta 1St Bhawan, Gate No.2, Floor, 11-A, Vishnu Digamber Marg, New Delhi-110002 Pan No.Aabct6254F (Appellant) (Respondent)

Section 143(3)Section 144Section 144C(13)Section 271Section 9

IN THE INCOME TAX APPLLATE TRIBUNAL DELHI BENCH ‘D’, NEW DELHI BEFORE SH. N. K. BILLAIYA, ACCOUNTANT MEMBER AND SH

Addl. CIT, Special Range-6, New Delhi vs. Nokia India Pvt. Ltd., New Delhi

ITA 1073/DEL/2018[2006-07]Status: DisposedITAT Delhi26 Nov 2021AY 2006-07

Bench: Shri Anil Chaturvedi & Shri Kuldip Singh(Through Video Conference) Addl.Cit, Spl. Range 6, Vs. M/S. Nokia India Pvt. Ltd., Unit No.1213, 12Th Floor, New Delhi. Kailash Building, Kasturba Gandhi Marg, New Delhi – 110 001. (Pan : Aaacn2170R) (Appellant) (Respondent)

For Appellant: Shri Deepak Chopra, AdvocateFor Respondent: Ms. Sarita Kumari, CIT DR
Section 140CSection 143(3)Section 144CSection 254

holding the Assessing Officer (the AO) failed to refer the order giving effects to findings and directions of the Hon'ble ITAT to Dispute Resolution Panel (DRP) u/s 144C of the Act?” 2. Briefly stated the facts necessary for adjudication of the controversy at hand are : Nokia India Private Limited

Bt Global Communications India Pvt. Ltd., New Delhi vs. Addl. CIT, Special Range- 2, New Delhi

In the result, appeal of the assessee is allowed

ITA 7576/DEL/2018[2014-15]Status: DisposedITAT Delhi25 Nov 2021AY 2014-15

Bench: Sh. Anil Chaturvedi & Sh. Kuldip Singh(Through Video Conferencing) Bt Global Communication Vs. Acit India Pvt. Ltd. Special Range – 2 11Th Floor, Eros Corporate New Delhi Tower, Opp. International Trade Tower, Nehru Place, New Delhi Pan No. Aaacg 1534 A (Appellant) (Respondent) Assessee By Shri Vishal Kalra, Adv. Revenue By Shri Satpal Gulati, Cit-D.R. Date Of Hearing: 18.11.2021 Date Of Pronouncement: 25.11.2021 Order Per Anil Chaturvedi, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of The Addl. Commissioner Of Income Tax – Special Range–2, New Delhi Under Section 143(3) R.W.S. 144C(13) Of The Act Pursuant To The Direction Of Dispute Resolution Panel (Drp) – 1, New Delhi Order Dated 27.08.2018 For Assessment Year 2014-15. 2. The Relevant Facts As Culled From The Material On Records Are As Under :

Section 143(3)Section 234BSection 271(1)(c)Section 274Section 35ASection 37

Income Tax – Special Range–2, New Delhi under section 143(3) r.w.s. 144C(13) of the Act pursuant to the direction of Dispute Resolution Panel (DRP) – 1, New Delhi order dated 27.08.2018 for Assessment Year 2014-15. 2. The relevant facts as culled from the material on records

Sumitomo Corporation India Pvt. Ltd, New Delhi vs. Neac, New Delhi

Accordingly, ITA number 508/del/2021 filed by the assessee for assessment year 2016 – 17 is partly allowed

ITA 508/DEL/2021[2016-17]Status: DisposedITAT Delhi24 Nov 2021AY 2016-17

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Himanshu Sinha, Adv.; &For Respondent: Shri Shashi Bhusan Shukla
Section 143(3)Section 144Section 144BSection 92CSection 92C(3)

profit level indicator ("PLI") has been disregarded without any justification whatsoever. 5. The Ld. AO / TPO has disregarded the directions of the Ld. Dispute Resolution Panel ("DRP"), wherein it is directed to the Ld. AO / TPO to ascertain whether an appeal has been filed against the order ... addition of Rs.23,58,56,325/- aggregating to Rs.40,71,91,523/- was made. 10 The assessee preferred an objection before the ld. Dispute Resolution Panel that passed its direction on 24th December 2020. In para No. 7.5.1 of the direction, the ld. DRP noted that if the Revenue

Sumitomo Corporation India Pvt. Ltd, New Delhi vs. Neac, New Delhi

Accordingly, ITA number 508/del/2021 filed by the assessee for assessment year 2016 – 17 is partly allowed

ITA 507/DEL/2021[2015-16]Status: DisposedITAT Delhi24 Nov 2021AY 2015-16

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Himanshu Sinha, Adv.; &For Respondent: Shri Shashi Bhusan Shukla
Section 143(3)Section 144Section 144BSection 92CSection 92C(3)

profit level indicator ("PLI") has been disregarded without any justification whatsoever. 5. The Ld. AO / TPO has disregarded the directions of the Ld. Dispute Resolution Panel ("DRP"), wherein it is directed to the Ld. AO / TPO to ascertain whether an appeal has been filed against the order ... addition of Rs.23,58,56,325/- aggregating to Rs.40,71,91,523/- was made. 10 The assessee preferred an objection before the ld. Dispute Resolution Panel that passed its direction on 24th December 2020. In para No. 7.5.1 of the direction, the ld. DRP noted that if the Revenue

Itochu Corporation, Japan vs. ACIT (International Taxation), Circle-2(1)(1), New Delhi

The appeals of the assessee are partly allowed for statistical purposes

ITA 7615/DEL/2018[2015-16]Status: DisposedITAT Delhi24 Nov 2021AY 2015-16

Bench: Shri R. K. Pandaa N D Ms. Suchitra Kamblei.T.A. No. 360/Del/2017 (A.Y. 2013-14) A N D I.T.A. No. 7615/Del/2018 (A.Y. 2015-16) (Through Video Conferencing) Itochu Corporation, Acit, 5–1, Kita-Aoyama, Vs. (International Taxation) 2–Chome, Minato-Ku Circle 2(1)(1), Tokyo 107-8077, Japan. New Delhi. Pan: Aabci5567L (Appellant) (Respondent)

For Appellant: Shri Ajay Vohra, Sr. Adv &For Respondent: Shri Satpal Gulati [CIT]–DR

360/Del/2017 (A.Y. 2013-14) : “ 1. On the facts, in the circumstances of the case and in law, the Ld. AO/ Hon’ble Dispute Resolution Panel (‘DRP’) has erred in alleging that Itochu India Private Limited (‘Itochu India’), appellant’s subsidiary in India and other agents constitute a dependent agent Permanent ... I.T.A. No. 7615/Del/2018 (A.Y. 2015-16) : ‘’ 1. On the facts, in the circumstances of the case and in law, the Ld. AO/ Ld. Dispute Resolution Panel (‘DRP’) has erred in alleging that Itochu India Private Limited (‘Itochu India’), appellant’s subsidiary in India and other agents constitute a dependent agent

Itochu Corporation, Japan vs. DCIT (International Taxation), New Delhi

The appeals of the assessee are partly allowed for statistical purposes

ITA 360/DEL/2017[2013-14]Status: DisposedITAT Delhi24 Nov 2021AY 2013-14

Bench: Shri R. K. Pandaa N D Ms. Suchitra Kamblei.T.A. No. 360/Del/2017 (A.Y. 2013-14) A N D I.T.A. No. 7615/Del/2018 (A.Y. 2015-16) (Through Video Conferencing) Itochu Corporation, Acit, 5–1, Kita-Aoyama, Vs. (International Taxation) 2–Chome, Minato-Ku Circle 2(1)(1), Tokyo 107-8077, Japan. New Delhi. Pan: Aabci5567L (Appellant) (Respondent)

For Appellant: Shri Ajay Vohra, Sr. Adv &For Respondent: Shri Satpal Gulati [CIT]–DR

360/Del/2017 (A.Y. 2013-14) : “ 1. On the facts, in the circumstances of the case and in law, the Ld. AO/ Hon’ble Dispute Resolution Panel (‘DRP’) has erred in alleging that Itochu India Private Limited (‘Itochu India’), appellant’s subsidiary in India and other agents constitute a dependent agent Permanent ... I.T.A. No. 7615/Del/2018 (A.Y. 2015-16) : ‘’ 1. On the facts, in the circumstances of the case and in law, the Ld. AO/ Ld. Dispute Resolution Panel (‘DRP’) has erred in alleging that Itochu India Private Limited (‘Itochu India’), appellant’s subsidiary in India and other agents constitute a dependent agent

Orange Business Services India Solutions Pvt. Ltd., Gurgaon vs. DCIT Circle- 3, Gurgaon

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

ITA 851/DEL/2021[2016-17]Status: DisposedITAT Delhi18 Nov 2021AY 2016-17

Bench: Shri O.P. Kant & Shri K.N. Chary[Through Video Conferencing] Assessment Year: 2016-17

Section 92CSection 92D

fact and circumstances of the case, and in law; 1. The Learned Assessing Officer (‘Ld. AO) (following the directions of the Learned Dispute Resolution Panel (‘Ld. DRP’)) erred on facts and in law in enhancing the income of the Appellant by Rs. 29,20,68,757 without appreciating the factual

Sona Blw Precision Forgings Ltd., New Delhi vs. DCIT, New Delhi

ITA 3134/DEL/2017[2012-13]Status: DisposedITAT Delhi18 Nov 2021AY 2012-13

Bench: Shri O.P. Kant & Ms. Suchitra Kamble[Through Video Conferencing]

Section 40Section 92BSection 92C

draft assessment order, the Assessing Officer proposed the transfer pricing adjustment. As the assessee did not opt filing objection before the Learned Dispute Resolution Panel ( DRP), the Assessing Officer passed impugned assessment order on the 08/03/2015 after including the addition for transfer pricing adjustment on account of guarantee fee. Aggrieved

Sona Okegawa Precision Forgings Ltd., New Delhi vs. DCIT, New Delhi

ITA 204/DEL/2017[2011-12]Status: DisposedITAT Delhi18 Nov 2021AY 2011-12

Bench: Shri O.P. Kant & Ms. Suchitra Kamble[Through Video Conferencing]

Section 40Section 92BSection 92C

draft assessment order, the Assessing Officer proposed the transfer pricing adjustment. As the assessee did not opt filing objection before the Learned Dispute Resolution Panel ( DRP), the Assessing Officer passed impugned assessment order on the 08/03/2015 after including the addition for transfer pricing adjustment on account of guarantee fee. Aggrieved

Lg Electronics Inc., Korea vs. DCIT Int. Taxation, Circle 2(2)(1), New Delhi

In the result, the appeals filed by the assessee in ITA Nos

ITA 653/DEL/2021[2014-15]Status: DisposedITAT Delhi17 Nov 2021AY 2014-15

Bench: Shri N.K. Billaiya & Shri Sudhanshu Srivastava

For Appellant: Shri Deepak Chopra, AdvFor Respondent: Mrs. Anupama Anand, CIT-DR
Section 147Section 263

under sub-section (3) of Section 92CA. For this class of assessees, it prescribes a collegium of three commissioners, once objections are preferred. Dispute Resolution Panel's powers are co-terminous with the CIT(A), including the power to confirm, reduce or enhance the variation proposed and to consider ... issues not agitated by the Assessee in the objections. In fact, under section 144C, the Dispute Resolution Panel can issue directions as it thinks fit for the guidance of the Assessing Officer to enable him to complete the assessment and the Dispute Resolution Panel can confirm, reduce or enhance

Lg Electronics Inc., Korea vs. DCIT Int. Taxation, Circle 2(2)(1), New Delhi

In the result, the appeals filed by the assessee in ITA Nos

ITA 652/DEL/2021[2013-14]Status: DisposedITAT Delhi17 Nov 2021AY 2013-14

Bench: Shri N.K. Billaiya & Shri Sudhanshu Srivastava

For Appellant: Shri Deepak Chopra, AdvFor Respondent: Mrs. Anupama Anand, CIT-DR
Section 147Section 263

under sub-section (3) of Section 92CA. For this class of assessees, it prescribes a collegium of three commissioners, once objections are preferred. Dispute Resolution Panel's powers are co-terminous with the CIT(A), including the power to confirm, reduce or enhance the variation proposed and to consider ... issues not agitated by the Assessee in the objections. In fact, under section 144C, the Dispute Resolution Panel can issue directions as it thinks fit for the guidance of the Assessing Officer to enable him to complete the assessment and the Dispute Resolution Panel can confirm, reduce or enhance

Lg Electronics Inc., Korea vs. DCIT Int. Taxation, Circle 2(2)(1), New Delhi

In the result, the appeals filed by the assessee in ITA Nos

ITA 651/DEL/2021[2009-10]Status: DisposedITAT Delhi17 Nov 2021AY 2009-10

Bench: Shri N.K. Billaiya & Shri Sudhanshu Srivastava

For Appellant: Shri Deepak Chopra, AdvFor Respondent: Mrs. Anupama Anand, CIT-DR
Section 147Section 263

under sub-section (3) of Section 92CA. For this class of assessees, it prescribes a collegium of three commissioners, once objections are preferred. Dispute Resolution Panel's powers are co-terminous with the CIT(A), including the power to confirm, reduce or enhance the variation proposed and to consider ... issues not agitated by the Assessee in the objections. In fact, under section 144C, the Dispute Resolution Panel can issue directions as it thinks fit for the guidance of the Assessing Officer to enable him to complete the assessment and the Dispute Resolution Panel can confirm, reduce or enhance