“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

DCIT, New Delhi vs. M/S. Kroll Associates (India) Pvt. Ltd., New Delhi

In the result, the appeal of Revenue is dismissed

ITA 1597/DEL/2016[2011-12]Status: DisposedITAT Delhi05 Aug 2021AY 2011-12

Bench: Sh. Anil Chaturvedi & Sh. K. Narasimha Chary(Through Video Conferencing) Dcit Vs. Kroll Associates (India) Pvt. Circle – 14(2), Ltd., New Delhi 708, Surya Kiran Building, K. G. Marg, Pan No. Aaack 5906 E New Delhi-110001 (Appellant) (Respondent) Assessee By Shri Surender Pal, Cit-D.R. Revenue By Ms. Soumya Singh & Ms. Ananya Kapoor, Adv. Date Of Hearing: 05.08.2021 Date Of Pronouncement: 05.08.2021 Order Per Anil Chaturvedi, Am: This Appeal Filed By The Revenue Is Directed Against The Order Of The Dy. Commissioner Of Income Tax - Circle-14(2), New Delhi Under Section 144C(5) Of The Act Pursuant To The Direction Of Dispute Resolution Panel (Drp) – I, New Delhi Order Dated 24.11.2015 For Assessment Year 2011-12. 2. Revenue Has Raised The Following Grounds Of Appeals: 1. “That The Directions Of The Ld. Drp Are Erroneous & Contrary To Facts & Law.

Section 144C(5)

Commissioner of Income Tax - Circle-14(2), New Delhi under section 144C(5) of the Act pursuant to the direction of Dispute Resolution Panel (DRP) – I, New Delhi order dated 24.11.2015 for Assessment Year 2011-12. 2. Revenue has raised the following grounds of appeals: 1. “That the directions

Hyatt International Southwest Asia Ltd., Dubai vs. ACIT, Circle- 2(1)(1), New Delhi

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

ITA 6179/DEL/2017[2014-15]Status: DisposedITAT Delhi27 Jul 2021AY 2014-15

Bench: Shri Kul Bharat & Shri O.P. Kant[Through Video Conferencing] Assessment Year: 2014-15

Section 2Section 9

section 2 144C(13) r.w.s. 143(3) of the Income-tax Act, 1961 (in short ‘the Act’) in pursuance to the direction of Dispute Resolution Panel, New Delhi. The grounds raised by the assessee are as under: Ground No. 1 - Alleged Permanent Establishment (‘PE’) in India of the Appellant under ... Treaty’) 1. On the facts and circumstances of the case and in law, the Assessing Officer (‘AO’) erred in concluding and the Dispute Resolution Panel (‘DRP’) erred in holding that the Appellant has a PE in India under Article 5(1) and 5(2)(i) of the Tax Treaty without

Jas Forwarding Worldwide Pvt. Ltd., Gurgaon vs. DCIT, New Delhi

In the result appeal of the assessee for assessment year 2011 – 12 is allowed for statistical purposes

ITA 1687/DEL/2016[2011-12]Status: DisposedITAT Delhi26 Jul 2021AY 2011-12

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Salil Kapoor advocateFor Respondent: Shri M. Barnwal, Sr. DR

Section 143Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 40Section 92CSection 92C(2)

Income Tax Act, 1961 ("the Act") is not in accordance with the law and therefore not sustainable. That the Hon'ble Dispute Resolution Panel, New Delhi ("the DRP") has erred both in law and on facts by summarily rejecting the Appellant's objections to the draft order passed ... comparability adjustment on account of risk of the comparable companies for the purpose of comparison with the results of the Assessee. 2.2 The Dispute Resolution Panel ('DRP') has not adjudicated on the issue pertaining to erroneous approach followed by the Ld. TPO by considering the Shipping Companies as comparable

Jas Forwarding Worldwide Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result appeal of the assessee for assessment year 2011 – 12 is allowed for statistical purposes

ITA 2484/DEL/2014[2009-10]Status: DisposedITAT Delhi26 Jul 2021AY 2009-10

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Salil Kapoor advocateFor Respondent: Shri Surendra Pal [CIT] – DR

Section 143Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 40Section 92CSection 92C(2)

Avaya India Private Limited, Mumbai vs. ACIT, Circle-1(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 466/DEL/2021[2016-17]Status: DisposedITAT Delhi09 Jul 2021AY 2016-17

Bench: Sh. Kul Bharatdr. B. R. R. Kumar(Through Video Conferencing) Ita No. 466/Del/2021 : Asstt. Year : 2016-17 Avaya India Pvt. Ltd., Vs Acit, 202, Platina, 2Nd Floor, Plot No. Circle-1(1), C-59, G-Block, Bandra Kurla New Delhi Complex, Bandra(E), Mumabi, Maharashtra-400051 (Appellant) (Respondent) Pan No. Aaeca3592N Assessee By : Sh. Kamal Sawhney, Adv. Revenue By : Sh. Surender Pal, Cit Dr Date Of Hearing: 05.07.2021 Date Of Pronouncement: 09.07.2021

For Appellant: Sh. Kamal Sawhney, AdvFor Respondent: Sh. Surender Pal, CIT DR

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

order framed by National e-Assessment Centre, Delhi (hereinafter referred to as “the Ld. AO") pursuant to the directions of the Hon'ble Dispute Resolution Panel - I (hereinafter referred to as “the Hon’ble DRP”) under section 143(3) read with section 144C(13) and read with sections ... deduction in respect of education cess. This is an additional ground filed, vide letter dated 17.8.2020, under Rule 7(4) of Income Tax (Dispute Resolution Panel) Rules 2009 and which reads as follows: "The assessee prays that the liability for education cess on income-tax paid for the year ought

M/S Contitech India Pvt. Ltd., New Delhi vs. ACIT, New Delhi

The appeal of the assessee is allowed

ITA 5222/DEL/2011[2007-08]Status: DisposedITAT Delhi22 Jun 2021AY 2007-08

Bench: Sh. Anil Chaturvedi & Sh. Kuldip Singh(Through Video Conferencing)

Section 143(3)Section 144CSection 14A

Commissioner of Income Tax, Circle-I, II & XI, New Delhi under section 144C of the Act pursuant to the direction of 2 Dispute Resolution Panel (DRP) – I, New Delhi order dated 30.08.2010 & 15.09.2011 for Assessment Years 2006-07 & 2007- 08. We first proceed with

M/S Contitech India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

The appeal of the assessee is allowed

ITA 5088/DEL/2010[2006-07]Status: DisposedITAT Delhi22 Jun 2021AY 2006-07

Bench: Sh. Anil Chaturvedi & Sh. Kuldip Singh(Through Video Conferencing)

Section 143(3)Section 144CSection 14A

Sumitomo Corporation, New Delhi vs. DCIT (International Taxation), New Delhi

Appeal of the assessee is partly allowed for statistical purpose

ITA 1881/DEL/2017[2013-14]Status: DisposedITAT Delhi09 Jun 2021AY 2013-14

Bench: Shri R. K. Panda & Ms Suchitra Kamble(Through Video Conferencing) Sumitomo Corporation Vs Dcit (International Taxation) G-195, Circle-3(1)(2) Sarita Vihar New Delhi New Delhi Aabcs6011P (Appellant) (Respondent)

Section 143(3)Section 144CSection 5

amounting to Rs. 69,26,60,776/-. The addition made of Rs. 3,81,61,252/- is highly misconceived and the Hon’ble Dispute Resolution Panel (Ld DRP) has also erred in not directing the said sum to be excluded. 2. That the Ld AO/DRP has failed to appreciate that ... compute total income of Rs. 74.16 crore. Aggrieved by the draft assessment order, the 7 assessee filed objections before the Dispute Resolution Panel (DRP). The DRP vide order dated 28/11/2016 gave certain directions to the Assessing Officer. The Assessing Officer vide order dated 31/1/2017 computed the income as follows:- Income

Keihin Automotive Systems India Pvt. Ltd., Gurgaon vs. DCIT, Circle- 2(1), Gurgaon

In the result, appeal of the assessee is partly allowed with about directions

ITA 7801/DEL/2017[2013-14]Status: DisposedITAT Delhi08 Jun 2021AY 2013-14

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Keihin Automotive Systems Pvt. Dcit, Ltd.[Now Amalgamated & Known As Vs. Keihin India Manufacturing Pvt. Ltd.,] Circle: 2 (1), Plot No. 663, Phase–5, Udyog Vihar, Gurgaon, Gurgaon. Haryana – 122 016. Pan: Aaeck4216F (Appellant) (Respondent)

For Appellant: Shri Pradeep Dinodia, C.AFor Respondent: Shri Surendra Pal [CIT] – DR

Section 143(3)Section 144CSection 234ASection 37Section 92C

read with Section 144C of the Income Tax Act, 1961 (the Act) dated 26.10.2017 pursuant to the direction of the ld. Dispute Resolution Panel–1, New Delhi, [ The LD DRP] dated 22.09.2017 wherein the adjustment proposed by the ld. DCIT, Transfer Pricing 1(3)(1), New Delhi ... capital expenditure and disallowed it. Consequent draft order was passed on 23/12/2016. 9. Against the draft order, assessee preferred objections before the ld. Dispute Resolution Panel. The ld. DRP issued its direction on 22.09.2017 wherein it gave direction as per para No. 3.5 stating that it is the first year

M/S. Saic India Private Limited, Noida vs. DCIT, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 6842/DEL/2014[2010-11]Status: DisposedITAT Delhi07 Jun 2021AY 2010-11

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Saic India Private Limited, Vs. Dcit, C/O. Wipro Energy It Services India Circle-7(1), Pvt. Ltd, New Delhi A-67, Sector-57, Noida Pan: Aaaci6192A (Appellant) (Respondent)

For Appellant: Manoneet Dalal, AdvFor Respondent: Shri Surendra Pal, CIT DR

Section 143(3)Section 144CSection 145Section 234BSection 92Section 92C

144C of the Income Tax Act, 1961 (the Act) on 14.10.2014 for assessment year 2010-11. Pursuant to the direction of the Ld. Dispute Resolution Panel–III, New Delhi, dated 19.08.2014, the assessee has raised the following grounds of appeal:- “I. Corporate Tax Grounds 1. That on the facts ... Income Tax Act, 1961 (“Act”). 6. That on facts and circumstances of the case and in law, the Ld. AO/Ld. TPO/Ld. Dispute Resolution Panel (“DRP”) erred in making an addition of Rs. 59,675,189/- to the returned income of the Appellant by re-computing the arm’s length price

Amadeus India Pvt. Ltd., New Delhi vs. ACIT, Circle 2(2), New Delhi

In the result, the appeal of assessee are allowed

ITA 8700/DEL/2019[2015-16]Status: DisposedITAT Delhi31 May 2021AY 2015-16

Bench: Sh. Anil Chaturvedi & Sh. Amit Shukla(Through Video Conferencing) Amadeus India Pvt. Ltd., Vs. Acit E-9, Connaught Hose, Circle – 2(2), Connaught Place, New Delhi New Delhi - 110001 Pan No. Aaaca 0364 L (Appellant) (Respondent) Assessee By Shri Taran Deep Singh, Adv. Revenue By Shri Surender Pal, Cit-D.R. Date Of Hearing: 18/05/2021 Date Of Pronouncement: 31/05/2021 Order Per Anil Chaturvedi, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.09.2019 Of The Asst. Commissioner Of Income Tax, Circle-2(2), Delhi Under Section 143(3) R.W.S 144C(13) Of The Act Pursuant To The Direction Of Dispute Resolution Panel (Drp) – 1, Delhi For Assessment Year 2015-16. 2. The Relevant Facts As Culled From The Material On Records Are As Under :

Section 143(2)Section 143(3)Section 144CSection 144C(2)Section 144C(5)Section 92BSection 92CSection 92C(3)Section 92F

Commissioner of Income Tax, Circle-2(2), Delhi under section 143(3) r.w.s 144C(13) of the Act pursuant to the direction of Dispute Resolution Panel (DRP) – 1, Delhi for Assessment Year 2015-16. 2. The relevant facts as culled from the material on records are as under : 3. Assessee ... following grounds: “1. That on facts and in law the orders passed by the Assessing officer [hereinafter referred to as the “AO”]/ Dispute Resolution Panel [hereinafter referred to as the “DRP]/Transfer Pricing Officer [hereinafter referred to as the “TPO ] are bad in law and void ab-initio. 2. That

Teradata Operations Inc., United States vs. DCIT, Circle- 3(1)(1), International Taxation, New Delhi

In the result, the appeal of the assessee is dismissed as withdrawn

ITA 7150/DEL/2019[2016-17]Status: DisposedITAT Delhi28 May 2021AY 2016-17

Bench: Shri G.S. Pannu & Shri Amit Shukla

Section 5(1)

assessee for the assessment year 2016-17 is directed against the final Assessment Order dated 01.07.2019 passed in pursuance to the direction of Dispute Resolution Panel (DRP), dated 12.06.2019. 2. The assessee, vide its letter dated 10.05.2021 received through email, has requested for withdrawal of the appeal and stated that

DCIT (International Taxation), New Delhi vs. M/S the Bank of Tokyo Mistubishi Ufj Ltd., New Delhi

The appeal of the assessee is allowed

ITA 283/DEL/2016[2011-12]Status: DisposedITAT Delhi27 May 2021AY 2011-12

Bench: Shri R.K. Panda & Shri Kuldip Singh(Through Video Conference)

For Appellant: Shri Nishant Takkar, AdvocateFor Respondent: Ms. Meera Srivastava, CIT DR

Section 115JSection 143Section 144CSection 2(17)Section 9

findings:- “39. We have carefully considered the rival contention and perused the orders of the lower authority and the direction of the learned dispute resolution panel. As in the case of the assessee In ITA No. 1162/Del/2014 for Assessment Year: 2009-10 dated 21/5/2020 has considered the identical issue

A.T. Kearney Ltd.- India Branch Office, Gurgaon vs. ADIT, New Delhi

In the result, the appeal of assessee is allowed

ITA 4405/DEL/2011[2003-04]Status: DisposedITAT Delhi25 May 2021AY 2003-04

Bench: Shri N.K. Billaiya & Shri Kuldip Singhआ.अ.सं/.I.T.A No.4405/Del/2011 िनधा"रणवष"/Assessment Year:2003-04 बनाम A.T. Kearney Ltd., Adit India Branch Office, Vs. Circle 1(1) 14Th Floor, Tower D, International Taxation, Global Business Park, New Delhi. Gurgaon.

Section 115ASection 143(3)Section 144CSection 144C(13)Section 234BSection 234DSection 244ASection 271(1)(c)Section 44D

Assistant Director of Income-tax (hereinafter referred to as ‘the Ld. Assessing Officer’) in pursuance to the directions of the Hon’ble Dispute Resolution Panel – 1 (hereinafter referred to as ‘the Ld. 1 I.T.A.No.4405/Del/2011/A.Y.2003-04 DRP’) under section 143(3) read with section 144C of the Income ... framed draft assessment order and thereafter final assessment orders were passed. Provisions of section 144C of the Act which relates to reference to Dispute resolutions Panel were inserted vide Finance Act [No. 2]] Act 2009 w.e.f. 01.04.2009. The provisions read as under: “The Assessing Officer shall, notwithstanding anything

Honda Motorcycle & Scooter India Pvt Ltd, Gurgaon vs. DCIT Circle- 2(1), Gurgaon

In the result, appeal of the assessee is partly allowed

ITA 9073/DEL/2019[2015-16]Status: DisposedITAT Delhi21 May 2021AY 2015-16

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Honda Motorcycle & Scooter Vs. Dcit, India Pvt. Ltd, Circle-2(1), Commercial Complex-Ii, Sector- Gurgaon 49 To 50, Gold Course Road, Extn Road, Gurgaon Pan: Aaach7467D (Appellant) (Respondent)

For Appellant: Shri Deepak Chopra, AdvFor Respondent: Shri Surender Pal, CIT DR

Section 143(3)Section 144CSection 153Section 92C

section 144C of The Income Tax Act (the Act) dated 30.12.2019 for Assessment Year 2015-16 in pursuance of direction issued by The Dispute Resolution Panel – 1, New Delhi (the learned DRP) u/s 144C (5) of the act dated 18 September 2019. 2. The assessee has raised following grounds ... application of the principles of commercial expediency and need test applied by the learned transfer pricing officer and confirmed by the learned dispute resolution panel. The ground number 6 along with its sub- grounds (14 in number) is in substance challenging the determination of the arm’s-length price

Ge Capital Business Process Management Services Pvt. Ltd., New Delhi vs. DCIT, New Delhi

The appeal of the assessee is partly allowed for statistical purpose

ITA 403/DEL/2017[2012-13]Status: DisposedITAT Delhi20 May 2021AY 2012-13

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A. No. 403/Del/2017 (A.Y 2012-13) (Through Physical Hearing) Sbi Business Process Vs Dcit Management Services Pvt. Ltd. Circle 10(1) Earlier Known As C. R. Building, I. P. Estate, Ge Capital Business Process New Delhi Management Services Pvt. Ltd. 401, 402, 4Th Floor, Aggarwal Millennium Tower, E- 1,2,3, Netaji Subhash Place, Wazirpur, New Delhi Pan: Aabcg0222E (Appellant) (Respondent)

Section 143(3)Section 144CSection 37(1)Section 92C(3)Section 92D

assessee were rejected. Subsequently, the DRP passed a rectification order dated March 24, 2017 under Rule 13 of the Income Tax (Dispute Resolution Panel) under which it directed the exclusion of BNR Udyog Ltd. from the final list of comparables. The assessment order dated 17/11/2016 was passed ... under Rule 13 of the Income Tax (Dispute Resolution Panel) Rules 2009 passed order dated 24/3/2017 thereby rectifying the earlier order. 4. Being aggrieved by the assessment order, the assessee filed appeal before us. 5. As regards to Ground No. 2.1 to 2.12 relating to Transfer pricing adjustment

Pepsico India Holdongs Pvt Ltd, Gurgaon vs. ACIT Central Circle-07, New Delhi

The appeal of the assessee is allowed and the Stay Application of the assessee is dismissed

ITA 113/DEL/2021[2016-17]Status: DisposedITAT Delhi04 May 2021AY 2016-17

Bench: Sh. Amit Shukladr. B. R. R. Kumarita No. 113/Del/2021 : Asstt. Year: 2016-17 Pepsico India Holdings Pvt. Ltd., Vs Acit, Level 3-6, Pioneer Square, Central Circle-07, Sector-62, Golf Course, Extension New Delhi Road, Gurgaon, Haryana-122101 (Appellantt (Respondent) Pan No. Aaacp1272G

For Appellant: Sh. Deepak Chopra, AdvFor Respondent: Ms. Meera Srivastava, CIT DR

Section 143(3)Section 92BSection 92CSection 92F

Transfer Pricing Adjustment on account of Advertisement, Marketing and Promotion (“AMP”) Expenses 3. That the Transfer Pricing Officer (“TPO”)/ Dispute Resolution Panel (“DRP”)/ AO have erred in computing and sustaining Transfer Pricing Adjustment on account of AMP Expenses to the tune of INR 571,69,91,000/-. 4. That

Weir Minerals (India) Private Ltd, New Delhi vs. Addlcit, Special Range-9, New Delhi

In the result, the appeal of the assessee is dismissed

ITA 6514/DEL/2017[2013-14]Status: DisposedITAT Delhi15 Apr 2021AY 2013-14

Bench: Shri G.S. Pannu & Shri Kul Bharatassessment Year : 2013-14

For Appellant: NoneFor Respondent: Shri. R.K. Gupta, Sr. DR

ORDER PER G.S. PANNU, VP : This appeal by the assessee for the assessment year 2013-14 is directed against the order of learned Dispute Resolution Panel-2, New Delhi dated 21.06.2017. . 2 ITA-6514/Del/2017 2. None appeared on behalf of the assessee at the time of Virtual Hearing before

Symantec Asia Pacific Pte Ltd., Singapore vs. DCIT (International Taxation), New Delhi

The appeal of the assessee is allowed

ITA 3013/DEL/2017[2014-15]Status: DisposedITAT Delhi15 Apr 2021AY 2014-15

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A. No. 3013/Del/2017 (A.Y 2014-15) (Through Video Conferencing) Symantec Asia Pacific Pte. Ltd. Vs Dcit (International 6, Temasek Boulevard, Taxation) #12-01 Sutec Tower Four Circle-3(1)(2), Room No. Singpore 419, Aaocs1828F Blokc E-2, Civic Centre, J. L. N. Marg, New Delhi (Appellant) (Respondent)

Section 143(3)Section 144C(13)Section 253Section 271

International Taxation, New Delhi (hereinafter referred to as ‘AO’) in pursuance of the directions issued by the 2 Hon’ble Dispute Resolution Panel - 2, New Delhi (hereinafter referred to as ‘DRP’).dated 10 February 2017 under section 143(3) of the Act read with section 144C

Hero Motocrop Ltd., New Delhi vs. ACIT, Circle- 11(1), New Delhi

The appeal of the assessee is partly allowed

ITA 9187/DEL/2019[2015-16]Status: DisposedITAT Delhi13 Apr 2021AY 2015-16

Bench: Shri Sudhanshu Srivastava & Shri O.P. Kantassessment Year: 2015-16

Section 115JSection 143(3)Section 144CSection 145ASection 80ISection 92C

which the order of the coordinate bench pertains to. On reading of the assessment order as well as the direction of the Ld. Dispute resolution panel it was not found that how the loss of the assessee was found to be normal when the assessee submitted that ... abnormal loss incurred by it during the course of manufacturing process. Further the Ld. dispute resolution panel has also stated that both the cost of normal and abnormal losses have to be loaded to the value of the closing stock is devoid of any merit as it is contrary