← All Phrases

“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

Sms Group Gmbh, New Delhi vs. ACIT, Circle-3(1)(2) Int. Taxation, New Delhi

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

ITA 1592/DEL/2022[2018-19]Status: DisposedITAT Delhi24 Dec 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Percy Pardiwala, Sr. AdvFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 143(3)Section 144C(5)

r.w.s. 144C(13) of the Income Tax Act, 1961 (for short ‘the Act’) in consonance with the order passed by the Dispute Resolution Panel (DRP) dated 17.03.2022 u/s 144C(5) of the Act. 2. Identical issues are involved and hence they are taken up together and disposed of by this ... /Del/2022 ITA No. 993 & 3297/Del/2023 MS Group Gmbh Taxation), Delhi (A.O) u/s 143(3) in pursuance of direction issued u/s 144C by Dispute Resolution Panel (DRP) is perverse, bad in law and void, being contrary to law and principles of natural justice. 2. That the learned A.O./DRP has erred

Sms Group Gmbh, New Delhi vs. ACIT, Circle-3(1)(2), Int. Taxation, New Delhi

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

ITA 1591/DEL/2022[2017-18]Status: DisposedITAT Delhi24 Dec 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Percy Pardiwala, Sr. AdvFor Respondent: Shri M. S. Nethrapal, CIT DR
Section 143(3)Section 144C(5)

r.w.s. 144C(13) of the Income Tax Act, 1961 (for short ‘the Act’) in consonance with the order passed by the Dispute Resolution Panel (DRP) dated 17.03.2022 u/s 144C(5) of the Act. 2. Identical issues are involved and hence they are taken up together and disposed of by this ... /Del/2022 ITA No. 993 & 3297/Del/2023 MS Group Gmbh Taxation), Delhi (A.O) u/s 143(3) in pursuance of direction issued u/s 144C by Dispute Resolution Panel (DRP) is perverse, bad in law and void, being contrary to law and principles of natural justice. 2. That the learned A.O./DRP has erred

M/S. Gulbrandsen Technologes (India) Pvt. Ltd, Vadodara vs. The ACIT, Circle-1(1)(1), Vadodara

ITA 160/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Makarand Vasant Mahadeokarआयकर अपील सं /Ita No. 160/Ahd/2022 िनधा"रण वष" /Assessment Year : 2017-18 M/S Gulbrandsen Additional/Joint/Deputy/ बनाम/ Technologies (India) Private Assistant Commissioner Of V/S. Limited Income Tax/Income-Tax 405, Synergy Square, Krishna Officer- Industrial Estate, Gowra, National Faceless Assessment Vadodara 390 016 Centre, Delhi "थायी लेखा सं./Pan: Aabcg 9006 E (अपीलाथ(/ Appellant) (") यथ(/ Respondent) Assessee By : Shri Mahesh Agarwal, Ar Revenue By : Shri Kalpesh Rupavatia, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 30/09/2025 घोषणा की तारीख /Date Of Pronouncement: 23/12/2025 आदेश/O R D E R

For Appellant: Shri Mahesh Agarwal, ARFor Respondent: Shri Kalpesh Rupavatia, Sr. DR
Section 143(3)Section 144CSection 144C(13)

u/s.143(3) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), in pursuance of the directions issued by the Dispute Resolution Panel (DRP) u/s.144C of the Act. relevant to Assessment Year (AY) 2017-18. 2. The assessee, in this appeal, has taken the following grounds of appeal

Ftsa Holdings B.V., Bengaluru vs. Deputy Commissioner of Income Tax, International Taxation, Circle 1(1)), Bangalore, Bengaluru

In the result ground No. 3-8 of the Appeal are allowed

ITA 643/BANG/2025[2019-2020]Status: DisposedITAT Bangalore23 Dec 2025AY 2019-2020

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year:2019-20 M/S. Ftsa Holdings B.V. The Deputy Commissioner C/O. Bbmp Khata, No. 937/138 Of Income Tax & 139/38/1, Sy. No. 138, International Taxation, Yelahanka Village &Hobli, Vs. Circle 1(1), Bengaluru - 560064 Bangalore. Pan: Aaecf0420A Appellant Respondent : Shri Aakash Uppal, Ca & Assessee By Shri Deepanshu Grovar, Ca : Shri Aseem Sharma, Cit-Dr Revenue By ` Date Of Hearing : 14-10-2025 Date Of Pronouncement : 23-12-2025

For Respondent: Shri Aakash Uppal, CA &
Section 131Section 142Section 147Section 148Section 69

Assessee is a foreign resident, draft Assessment Order was passed on 29.03.2024. 4. Aggrieved by the draft Assessment Order, theAssessee preferred objections withthe Dispute Resolution Panel at Bangalore who passed the direction that as Assessee has furnished additional evidences including form No. FC–GPR, bank statement showing the remittances, certificate ... However, Ld. DRP observed that in additional evidence the Assessee has not provided any evidence to show source of the investment. The Ld. Dispute Resolution Panel made a further observation that Page 3 of 11 Assessee has not provided even a shred of evidence to show source of these investments

DCIT(It), Circle-1, Pune vs. East West Seeds India Private Limited, Aurangabad

In the result, appeal filed by the Revenue is dismissed

ITA 858/PUN/2025[2020-21]Status: DisposedITAT Pune19 Dec 2025AY 2020-21

Bench: PER DR. DIPAK P. RIPOTE (Accountant Member)

Section 201Section 250Section 9(1)(vii)

held that "fee for technical services" cannot be taxed under the residual Article 22 of the Indo-Thailand DTAA. 3.4.10 DRP Order: The Dispute Resolution Panel in an order in Appellant's own case in a previous assessment year took the stand that the payment made by the Appellant towards ... order of the Assessing Officer. 6. Ld.Authorised Representative(ld.AR) for the Assessee submitted that for A.Y.2011-12 in assessee’s own case, Dispute Resolution Panel[DRP] had held that payment towards R & D Charges are in the nature of business receipts and same would be not liable for tax deductions

DCIT(It), Circle-1, Pune vs. East West Seeds India Private Limited, Aurangabad

In the result, appeal filed by the Revenue is dismissed

ITA 857/PUN/2025[2019-20]Status: DisposedITAT Pune19 Dec 2025AY 2019-20

Bench: PER DR. DIPAK P. RIPOTE (Accountant Member)

Section 201Section 250Section 9(1)(vii)

held that "fee for technical services" cannot be taxed under the residual Article 22 of the Indo-Thailand DTAA. 3.4.10 DRP Order: The Dispute Resolution Panel in an order in Appellant's own case in a previous assessment year took the stand that the payment made by the Appellant towards ... order of the Assessing Officer. 6. Ld.Authorised Representative(ld.AR) for the Assessee submitted that for A.Y.2011-12 in assessee’s own case, Dispute Resolution Panel[DRP] had held that payment towards R & D Charges are in the nature of business receipts and same would be not liable for tax deductions

DCIT(It), Circle-1, Pune vs. East West Seeds India Private Limited, Aurangabad

In the result, appeal filed by the Revenue is dismissed

ITA 833/PUN/2025[2018-19]Status: DisposedITAT Pune19 Dec 2025AY 2018-19
Section 201Section 250Section 9(1)(vii)

held that "fee for technical services" cannot be taxed under the residual Article 22 of the Indo-Thailand DTAA. 3.4.10 DRP Order: The Dispute Resolution Panel in an order in Appellant's own case in a previous assessment year took the stand that the payment made by the Appellant towards ... order of the Assessing Officer. 6. Ld.Authorised Representative(ld.AR) for the Assessee submitted that for A.Y.2011-12 in assessee’s own case, Dispute Resolution Panel[DRP] had held that payment towards R & D Charges are in the nature of business receipts and same would be not liable for tax deductions

Shakti Hormann Private Limited, Hyderabad vs. DCIT, Circle-3(1), Hyderabad

ITA 917/HYD/2024[2020-21]Status: DisposedITAT Hyderabad19 Dec 2025AY 2020-21

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.917/Hyd/2024 (निर्धारण वर्ष/Assessment Year:2020-21) Shakti Hormann Private Limited, Hyderabad. Vs. Dcit, Circle-3(1), Hyderabad. Pan: Aadcs4024Q (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri P. Murali Mohan Rao, Ca राजस्व द्वारा / Revenue By: Ms. U. Mini Chandran, Cit-Dr सुनवाई की तारीख /Date Of Hearing: 15/10/2025 घोषणा की तारीख / Date Of 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Final Assessment Order Passed By The Assessing Officer (For Short, “A.O.”) Under Section 143(3) R.W.S 144C(13) R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”) Dated 25/07/2024 For The

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Ms. U. Mini Chandran
Section 143(3)Section 144CSection 153Section 92C

adjustments, he proposed to assess the income of the assessee company at Rs.17,30,69,808/-. The assessee company filed objections before the Dispute Resolution Panel (DRP)-1, Bangalore in Form-35 on 20/10/2023. 7. The DRP-1, Bangalore, after considering the objections, issued directions under section 144C

Eaton Power Quality Private Limited, Puducherry vs. The Deputy Commissioner of Income Tax, Puducherry

In the result, appeal filed by the assessee is allowed

ITA 231/CHNY/2025[2021-22]Status: DisposedITAT Chennai18 Dec 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.Vishal Kalra, AdvocateFor Respondent: Mr. ARV Sreenivasan, CIT
Section 143Section 143(3)Section 144CSection 144C(1)Section 144C(13)Section 153Section 153(1)Section 92C

would be gainful to reproduce the relevant provisions of Sec.144C(13) of the Act, which reads as under: Section 144C [ Reference to dispute resolution panel] (1) ….. (2) ….. (3) ….. (4) ….. (5) ….. (6) ….. (7) ….. M/s. Eaton Power Quality Pvt. Ltd. :: 3 :: (8) ….. (9) ….. (10) ….. (11) ….. (12) ….. (13) Upon receipt of the directions ... month in which such direction is received.[emphasis given] 5. According to the Ld.AR, upon receipt of the directions of Dispute Resolution Panel (DRP), the AO should complete the final assessment as per section 144C(13) of the Act, i.e. within one month from the end of the month

Corteva Agriscience Seeds Pvt Ltd Tax (Formerly Known As Phi Seeds Pvt Ltd.), Telangana vs. ACIT, Circle 19(1), New Delhi

In the result, assessee’s appeal in ITA No

ITA 2575/DEL/2022[2018-19]Status: DisposedITAT Delhi18 Dec 2025AY 2018-19

Bench: Ms. Madhumita Roy & Smt. Renu Jauhriassessment Year: 2018-19

Section 143(3)Section 144Section 144CSection 144C(13)Section 144C(5)Section 153Section 92C

r.w.s. 144C(13) of the Income Tax Act, 1961 2 (hereinafter referred to as “the Act”), pursuant to the directions of the Dispute Resolution Panel (“DRP”) under Section 144C(5) of the Act for the Assessment Year 2018-19. 2. The assessee has raised additional ground of appeal in terms ... thus, illegal, bad in law and void-ab-initio. 4. That on the facts and circumstances of the case and in law, the Dispute Resolution Panel (DRP) erred in not quoting computer generated Document Identification Number ("DIN") on the body of DRP order directions dated 27.06.2022 issued under section

Marelli Um Electronic Systems Private Limited, Gurgaon vs. Deputy Commissioner of Income Tax/ Assessment Unit, Income Tax Department, Delhi

The appeal of the assessee is allowed with a direction to grant

ITA 5805/DEL/2024[2021-22]Status: DisposedITAT Delhi17 Dec 2025AY 2021-22

Bench: Shri Anubhav Sharma & Shri Amitabh Shuklamarelli Um Electronic Vs. Dcit/Assessment Unit, Systems Private Limited Income Tax Department 402, Sector-8, Imt Circle 16(1) Manesar Gurugram, Delhi, Cr Building Gurgaon – 122051 Delhi – 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aafcm8906R Appellant .. Respondent

For Appellant: Sh. Aditya Vohra, AdvFor Respondent: Ms. Ankush Kalra. Sr. DR
Section 143(3)Section 144C(5)

Marelli Um Electronic Systems Pvt. Ltd. (AY: 2021-22) Tax Act, 1961 in consonance with the Direction of the Ld. Dispute Resolution Panel (in short ‘DRP’) -1, New Delhi dated 20.09.2024 passed under Section 144C(5) of the Income Tax Act, 1961 for AY: 2021-22. 2. On hearing both ... this draft assessment order u/s 143(3) r.w.s 144B r.w.s 144C(1) of the I.T. Act, the assessee filed a petition before the Dispute resolution panel on P a g e | 6 Marelli Um Electronic Systems Pvt. Ltd. (AY: 2021-22) 16.01.2024 raising objection to the proposed addition

Eli Lilly and Company (India) Private Ltd., Haryana vs. ACIT Circle-1(1), Haryana

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

ITA 973/DEL/2022[2018-19]Status: DisposedITAT Delhi17 Dec 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Amitabh Shukla[Assessment Year:2018-19] Eli Lilly & Company Assistant Commissioner Of Income (India) Private Limited (‘Eli Tax, Circle-1(1), Haryana, Lilly India”) Vs Additional/Joint/Deputy/Income Plot No.92, Sector-32, Tax Officer/National Faceless Institutional Area, Jharsa, Appeal Centre, Gurgaon, Haryana-122001 New Delhi Pan Aaace8901F Appellant Respondent Assessee By Shri K. M. Gupta, Adv. & Shri Jaskaran Singh, Ar Revenue By Shri Dharm Veer Singh, Cit(Dr) Date Of Hearing 15.12.2025 Date Of Pronouncement 17.12.2025

Section 143(3)Section 144Section 144BSection 270ASection 92C(3)Section 92D

Commissioner of Income-tax/ Income-tax Officer, National Faceless Assessment Centre, Delhi (Ld. AO') pursuant to the directions passed by the Hon'ble Dispute Resolution Panel ("Hon'ble DRP') is bad in law and void. 2. That on the facts and circumstances of the case ... verify the computation and take remedial action, if found necessary.” 4. The learned Transfer Pricing Officer in response, to above directions of learned Dispute Resolution Panel, passed an order dated 08.03.2022, which is reproduced as under:- “……2. The assessee filed objection before the DRP-1, New Delhi, wherein the assessee

Satia Industries Limited, Muktsar vs. DCIT/ACIT Circle I, Bathinda

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

ITA 702/ASR/2024[2021-22]Status: DisposedITAT Amritsar16 Dec 2025AY 2021-22

Bench: Dr. M. L. Meena & Sh. Udayan Dasgupta

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 143(3)Section 144C(1)Section 144C(2)Section 144C(5)Section 80Section 80GSection 80ISection 92C

lakhs u/s 80G of the Act, against which objections raised by the assessee on 11th January, 2024, u/s 144C(2) with the DRP ( Dispute Resolution Panel) , culminated in the directions from DRP u/s 144C(5) vide order dated 30th September, 2024, where the adjustments were revised ... transmission loss from the unit price of electricity, which was not warranted. 2.1 That the Assessing Officer (AO), on the directions of the Dispute Resolution Panel (DRP), has erred in confirming the arm's length price of power transferred from the specified to the non-specified unit at an adjusted

M/S Scania Commercial Vehicles India Pvt Ltfd, Bangalore vs. Deputy Commissioner of Income Tax Circle-6(1)(1), Bangalore

The Appeal of the Assessee is allowed

ITA 261/BANG/2022[2017-18]Status: DisposedITAT Bangalore16 Dec 2025AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubey

For Appellant: Shri Narendra Kumar Jain, Advocate
Section 143(3)Section 68Section 92C

return of income on 30.11.2017 at a total loss of Rs. 306,57,86,824/- wherein after the direction of the Ld. Dispute Resolution Panel, the Ld. Assessing Officer retained three disallowance/additions as under:- a. Depreciation claim of Rs. 2,14,45,821/- pertaining to the new assets purchased ... addition of the total purchases of the fixed assets at Rs. 17,80,37,774/-. The issue was challenged before the Ld. Dispute Resolution Panel by objection no. 15 where the objection of the Assessee was allowed, and Ld. Assessing Officer was directed to examine the facts and consider

Raghavendra Ramakrishna Naik, Mumbai vs. ITO Int Tax Ward 3(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 2027/MUM/2025[2016-17]Status: DisposedITAT Mumbai16 Dec 2025AY 2016-17

Bench: Ms. Suchitra Raghunath Kamble & Shri Girish Agrawalassessment Year: 2016-17 Raghavendra Ramakrishna Vs Income Tax Officer, Ward Naik 3(3)(1), Mumbai Raghavendra Ramakrishna Room No. 626, 6Th Floor, Naik D-1, Flat No. 7, Navyouak Kautilya Bhavan, C-41 To C-43, Society, Bhandup East, G Block, Bandra Kurla Mumbai 400042 Complex, Bandra (East), Mumbai 400051 Pan: (Afapn9077M) Appellant Respondent Present For: Appellant By : Ms. Manisha Thakkar, Ca Respondent By : Shri. Krishna Kumar, Sr. Dr Date Of Hearing : 17.09.2025 Date Of Pronouncement : 16.12.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Final Assessment Order Passed By Ld. Ito (Intl. Tax) Ward 3(3)(1), Mumbai-3 Vide Order No. Itba/Com/F/17/2024-25/1072645237(1) Dated 28.01.2025 Passed Pursuant To The Directions Of The Ld. Dispute Resolution Panel U/S. 144C(5) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 02.12.2024 For Ay 2016-17. 2. Grounds Taken By The Assessee Are Reproduced As Under: “1. The Applicant States That The Learned Income Tax Officer Has Erred In Passing The Order Which Is Illegal, Arbitrary & Against The Principle Laid

For Appellant: Ms. Manisha Thakkar, CAFor Respondent: Shri. Krishna Kumar, Sr. DR
Section 144CSection 144C(1)Section 144C(5)Section 148Section 56(2)Section 56(2)(vii)Section 56(2)(x)

Intl. Tax) Ward 3(3)(1), Mumbai-3 vide Order No. ITBA/COM/F/17/2024-25/1072645237(1) dated 28.01.2025 passed pursuant to the Directions of the ld. Dispute Resolution Panel u/s. 144C(5) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), dated 02.12.2024 for AY 2016-17. 2. Grounds taken

Damandeep Kaur, Mohali vs. Assistant Commissioner of Income Tax (Central Circle-2), Chandigarh

In the result, all appeals of the assessee are allowed

ITA 902/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh15 Dec 2025AY 2020-21
For Appellant: Shri Rohit Kapoor, Advocate &For Respondent: Shri Manav Bansal, CIT, DR
Section 10(3)Section 153ASection 245D(4)

Officer or not. In this regard it would be appropriate to produce the provision of section 144C which provides as under: [Reference to dispute resolution panel. 83 144C. (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward4 a draft ... 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. (15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three [Principal Commissioners

Damandeep Kaur, Mohali vs. Assistant Commissioner of Income Tax (Central Circle-2), Chandigarh

In the result, all appeals of the assessee are allowed

ITA 901/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh15 Dec 2025AY 2019-20
Section 10(3)Section 153ASection 245D(4)

Officer or not. In this regard it would be appropriate to produce the provision of section 144C which provides as under: [Reference to dispute resolution panel. 83 144C. (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward4 a draft ... 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. (15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three [Principal Commissioners

Damandeep Kaur, Mohali vs. Assistant Commissioner of Income Tax (Central Circle-2), Chandigarh

In the result, all appeals of the assessee are allowed

ITA 900/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh15 Dec 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Rohit Kapoor, Advocate &For Respondent: Shri Manav Bansal, CIT, DR
Section 10(3)Section 153ASection 245D(4)

this regard it would be appropriate to produce the provision of section 144C which provides as under: 14 [Reference to dispute resolution panel. 83 144C. (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward84 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. (15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three 90[Principal

Damandeep Kaur, Mohali vs. Assistant Commissioner of Income Tax (Central Circle-2), Chandigarh

In the result, all appeals of the assessee are allowed

ITA 899/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh15 Dec 2025AY 2016-17
For Appellant: Shri Rohit Kapoor, Advocate &For Respondent: Shri Manav Bansal, CIT, DR
Section 10(3)Section 153ASection 245D(4)

Officer or not. In this regard it would be appropriate to produce the provision of section 144C which provides as under: [Reference to dispute resolution panel. 83 144C. (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward4 a draft ... 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. (15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three [Principal Commissioners

Joshi Technologies International Inc India Projects, Ahmedabad vs. The ACIT (Int. Taxa-1), Ahmedabad

In the result, all the three appeals filed by the assessee are partly allowed

ITA 81/AHD/2022[2018-19]Status: DisposedITAT Ahmedabad12 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

For Appellant: Shri Vishal Kalra, A.RFor Respondent: Shri Sher Singh, CIT-D.R
Section 143(3)Section 32Section 80I

without prejudice to each other. 1. The order passed by the Assessing officer w/s 143(3) in pursuance of the order of Dispute Resolution Panel us 144C, is erroneous and requires to be modified it is submitted that it be so held now. 2. The learned AO erred in disallowing ... without prejudice to each other. 1. The order passed by the Assessing officer u/s 143(3), in pursuance of the order of Dispute Resolution Panel u/s 144C, is erroneous and requires to be modified. It is submitted that it be so held now. 2. The learned AO erred in disallowing