“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

Franklin Templeton International Services (India) P.Ltd, Mumbai vs. DCIT Cir 3(1), Mumbai

In the result, appeals filed by the assessee stands partly allowed

ITA 2047/MUM/2014[2009-10]Status: DisposedITAT Mumbai20 Feb 2026AY 2009-10

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 133(6)Section 92D

circumstances of the case, the learned Transfer Pricing Officer ('TPO') and the learned Assessing Officer ('AO') under the directions of the Hon'ble Dispute Resolution Panel ('DRP') erred on facts and in law in making an addition ... circumstances of the case, the learned Transfer Pricing Officer ('TPO') and the learned Assessing Officer ('AO') under the directions of the Hon'ble Dispute Resolution Panel ('DRP') erred on facts and in law in making an addition

Assistant Commissioner of Income Tax, Dehradun vs. Seabird Exploration Fz-Llc, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 134/DDN/2024[2012-13]Status: DisposedITAT Dehradun18 Feb 2026AY 2012-13

Bench: SHRI YOGESH KUMAR U.S (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 250Section 271(1)(c)Section 44B

order and the total income was proposed at INR 28,83,36,180/-. Thereafter the assessee filed objections before the ld. Dispute Resolution Panel (“DRP”) who vide order dated 03.04.2019 has confirmed the addition on account of income @ 10 % computed u/s 44BB of the Act and delete the adjustment proposed

Teejay India Private Limited, Visakhapatnam vs. Deputy Commissioner of Income Tax, Circle-5(1), Visakhapatnam

ITA 533/VIZ/2024[2021-22]Status: DisposedITAT Visakhapatnam18 Feb 2026AY 2021-22

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Section 143(1)Section 143(3)Section 144C(1)Section 92C

Assessed Income as per intimation order u/s 143(1) of the Income-tax Act, 1961 (the Act). 3. That the learned Dispute Resolution Panel-1, Bengaluru ('learned DRP') erred in not appreciating that the order of the learned Deputy Commissioner of Income-tax DC/ACIT TP-3, Hyderabad ('learned TPO') passed ... proposed by the A.O vide his draft order passed under section 143(3) r.w.s. 144C(1) of the Act dated 08.12.2023 before the Dispute Resolution Panel-1, Bangalore (for short, “DRP”). However, the DRP did not find favour with the contentions advanced by the assessee-company and upheld the additions

Johnson Praveen Quadros, Australia vs. Income Tax Officer, Intl Tax Ward 3(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 5778/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Feb 2026AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2017-18 Johnson Praveen Quadros Income Tax Officer, Intl Tax Australia Ward 3 (3)(1) C/0 Room No.626, 6Th Floor, E 602, Nazrene Appts Marve Kautilya Bhavan, G Block, Vs. Road, Kharodi Malad West Bkc, Bandra (East), Mumbai 400095 Mumbai-400051 Maharashtra (Pan: Aacpq0820G) (Appellant) (Respondent) Present For: Assessee : Shri Anoop Kumar Agarwal, Ca Revenue : Shri Krishna Kumar, Sr. Dr Date Of Hearing : 20.11.2025 Date Of Pronouncement : 17.02.2026 O R D E R Per Girish Agrawal: 1. This Appeal Filed By The Assessee Is Against The Final Assessment Order Passed By The Assessing Officer U/S.147 R.W.S. 144C(13) Of The Act Dated 28.08.2025, Pursuant To The Direction Issued By The Ld. Dispute Resolution Panel – 1, Mumbai Vide Order Dated 28.07.2025 Vide Order No. Itba/Drp/F/144C(5)/2025-26/1078981626(1) Dated 28.07.2025 U/S. 144C(5) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), For Ay 2017-18. 2. Grounds Taken By The Assessee Are Reproduced As Under:

For Appellant: Shri Anoop Kumar Agarwal, CAFor Respondent: Shri Krishna Kumar, Sr. DR

Section 144C(5)Section 147Section 148Section 69

order passed by the Assessing Officer u/s.147 r.w.s. 144C(13) of the Act dated 28.08.2025, pursuant to the direction issued by the ld. Dispute Resolution Panel – 1, Mumbai vide order dated 28.07.2025 vide order no. ITBA/DRP/F/144C(5)/2025-26/1078981626(1) dated 28.07.2025 u/s. 144C(5) of the Income ... assessee are reproduced as under: 2 Johnson Praveen Quadros, AY 2017-18 1.0 On the facts and circumstances of the case, the Dispute Resolution Panel, Mumbai has grossly erred in dismissing the appellant's objections on mere presumptions and without thoroughly examining the facts and evidence presented, and confirming

Jagdeep Singh Dhanoa, United Arab vs. Income Tax Officer It 2(1) (1), Mumbai

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

ITA 1681/MUM/2022[2017-18]Status: DisposedITAT Mumbai17 Feb 2026AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarjagdeep Singh Dhanoa Vs. Income Tax Officer, 8202, 23 Marina, Po Pox It (2)(1), Mumbai 73392, Dubai Marina Dubai 1724, 17Th Floor, Air Ar, Foreign, India Building, United Arab Emirates- Nariman Point, 73392 Mumbai - 400021 Pan/Gir No. Aadpd4843R (Applicant) (Respondent) Assessee By None Revenue By Shri Krishna Kumar (Sr. Dr.) Date Of Hearing 03.02.2026 Date Of Pronouncement 17.02.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 26.04.2022 Passed U/S 143(3) R.W.S. 144C Of The Income Tax Act, 1961 (‘The Act’), By The Office Of The Income Tax Officer Ward 2(1) (1), Mumbai For The Assessment Year 2017-18. The Following Grounds Are Reproduced Below:

Section 143(3)Section 234ASection 234B

total income of the Appellant in respect of notional interest on loan granted to Associated Enterprises ('AE's') in India: 1.1 The Ld. Dispute Resolution Panel-1, Mumbai (DRP) erred in upholding the adjustment of INR 2,63,12,929 made by the Dy. Commissioner of Income

Movate Technologies Private Limited, Chennai vs. Deputy Commissioner of Income Tax, Chennai

In the result the appeal of the Assessee is partly allowed for statistical purposes

ITA 2467/CHNY/2024[AY 2020-21]Status: DisposedITAT Chennai16 Feb 2026

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri. ARV Sreenivasan, CIT

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

r.w.s 92CA (3) of the Act. 4. Being aggrieved by the order of the AO, the assessee had filed an objections before the Dispute Resolution Panel (hereinafter referred to as “DRP”). On perusal of the objections and after providing opportunity to the Assessee, the DRP issued directions u/s.144C

Saikat Chinmay Bhattacharya, Mumbai vs. Dy. CIT, International Taxation, Circle 1(1), Bangalore

ITA 582/BANG/2025[2015-16]Status: DisposedITAT Bangalore16 Feb 2026AY 2015-16

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyit(It)A No.582/Bang/2025

For Appellant: CA Darshit Naik, A.RFor Respondent: Dr. Divya K.J, CIT D.R

Section 147Section 148Section 69

support of his claim that the said amount of Rs.76,70,000/- was a gift received from his sister. 5. The Learned Dispute Resolution Panel erred in rejecting to application filed by the Appellant without appreciate to the facts and circumstances of the matter. 6. The Learned Dispute Resolution Panel

Arun Duraiswamy, Mysore, Karnataka vs. ITO, Intl. Taxation Ward 1(1), Bangalore

In the result the appeal filed by the assessee is allowed

ITA 193/BANG/2025[2015-16]Status: DisposedITAT Bangalore16 Feb 2026AY 2015-16

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: CA Deepak Gunashekar, A.RFor Respondent: Dr. Divya K.J, CIT D.R

Section 139Section 147Section 148Section 148ASection 149Section 69Section 69C

following grounds of appeal: - The appellant objects to the order of the Ld. AO u/s. 147 in pursuance of the directions of the Dispute Resolution Panel order on the grounds that: IT(IT)A No.193/Bang/2025 Arun Duraiswamy, Mysore Page 2 of 23 Grounds Raised Tax Effect ... order of the Ld. AO u/s. 147 of the Income Tax Act, 1961 in pursuance of the directions of the Dispute Resolution panel in so General Ground far as it is prejudicial to the interest of the Appellant is opposed to facts and law. 2. The order

Sureshkumar Kasturram Purohit, Ahmedabad vs. Income Tax Officer, Int. Tax, Ward - 2, Ahmedabad

ITA 386/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2016-17

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143Section 144CSection 148Section 69

raising the following Grounds of Appeal: I.T.A No. 386/Ahd/2025 A.Y. 2016-17 Page No 3 Sureshkumar Kasturram Purohit vs. ITO 1. The Dispute Resolution Panel, hereinafter referred to as the "DRP", has erred in confirming the addition to the extent

Mckinsey & Company India LLP, Delhi vs. ACIT, Circle-29(1), Delhi

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

ITA 1028/DEL/2021[2016-17]Status: DisposedITAT Delhi13 Feb 2026AY 2016-17

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh

Section 143(3)Section 144C(3)Section 253Section 271(1)(c)

r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as “the Act”), pursuant to the directions of the Hon'ble Dispute Resolution Panel (DRP) order dated 30.09.2020 for Assessment Year 2016-17. ITA No.- 1028/Del/2021 McKinsey & Company India LLP 2. When the matter was called for hearing, none

Mcdonald'S Corporation, New Delhi vs. DCIT, Circle- 2(2)(1), International Taxation, New Delhi

In the result, all the three appeals filed by the assessee for AY 2012-13, AY

ITA 3847/DEL/2018[2014-15]Status: DisposedITAT Delhi13 Feb 2026AY 2014-15

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh

Section 295(2)(h)

assessee are directed against the respective assessment orders dated 07.11.2016,13.07.2017 and 27.03.2018 pursuant to the directions of the Hon’ble Dispute Resolution Panel (DRP) order dated 26.10.2016, 31.05.2017 and 01.02.2018 for Assessment Years (AYs.) 2012-13, 2013-14 and 2014-15. Since common issues are involved, these three appeals

Mcdonald'S Corporation, New Delhi vs. DCIT, Circle- 2(2)(1), Intl. Taxation, New Delhi

In the result, all the three appeals filed by the assessee for AY 2012-13, AY

ITA 5609/DEL/2017[2013-14]Status: DisposedITAT Delhi13 Feb 2026AY 2013-14

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh

Section 295(2)(h)

Mcdonald'S Corporation, New Delhi vs. ACIT (International Taxation), New Delhi

In the result, all the three appeals filed by the assessee for AY 2012-13, AY

ITA 211/DEL/2017[2012-13]Status: DisposedITAT Delhi13 Feb 2026AY 2012-13

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh

Section 295(2)(h)

Firstrand Bank Limited, Mumbai vs. The Assistant Comm. of Income Tax-Circle-2(3)(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 2502/MUM/2022[2018-2019]Status: DisposedITAT Mumbai12 Feb 2026AY 2018-2019

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2018-19 Firstrand Bank Limited The Assistant Commissioner Of C-53, G-Block, 5 Th Floor, Income-Tax, Tcg Financial Centre, Circle-2(3)(1), Bandra-Kurla Complex, Mumbai Vs. Bandra (East)., Mumbai -400051 (Pan: Aabcf1632P) (Appellant) (Respondent) Present For: Assessee : Shri Paras Savla, Advocate Revenue : Shri Annavaram K, Sr. Dr Date Of Hearing : 14.11.2025 Date Of Pronouncement : 12.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Final Assessment Order Passed Pursuant To The Directions Of Ld. Dispute Resolution Panel- 1, Mumbai, Vide Order No. Itba/Drp/F/144C(5)/2022- 23/1043517868(1), Dated 22.06.2022, Passed U/S. 144C(5) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), For Assessment Year 2018-19. 2. Grounds Taken By The Assessee Are Reproduced As Under:

For Appellant: Shri Paras Savla, AdvocateFor Respondent: Shri Annavaram K, Sr. DR

Section 144C(5)Section 40Section 9(1)(vi)

GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the final assessment order passed pursuant to the directions of ld. Dispute Resolution Panel- 1, Mumbai, vide order no. ITBA/DRP/F/144C(5)/2022- 23/1043517868(1), dated 22.06.2022, passed u/s. 144C(5) of the Income-tax Act, 1961 (hereinafter referred ... Transfer Pricing adjustment in respect of provision of investment advisory services 1:1 The Assessing Officer ("AO")/ Transfer Pricing Officer ("TPO")/ Dispute Resolution Panel ("DRP") has erred in making upward adjustment of Rs. 73,44,923/- without appreciating the detailed analysis carried out by the Appellant in terms of determination

Shell International Petroleum Company Limited, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation )-4(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 1751/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Feb 2026AY 2022-23

Bench: Shri Amit Shukla & Shri Girish Agrawalshell International Petroleum Vs Deputy Commissioner Of Company Limited Income Tax (International C/O B S R & Co. Llp, 2Nd Floor, Taxation) 4(2)(1), Lodhaexcelus, Apollo Mills Mumbai Compound, N.M. Joshi Marg, Mahalakshmi, Mumbai 400011

For Appellant: Shri Madhur Agarwal and Shreyas Sardesai, AdvocatesFor Respondent: Shri Satya Pal Kumar, CIT DR

Section 144C(5)Section 2(24)Section 234BSection 9(1)(vi)

GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the final assessment order passed pursuant to the directions of Id. Dispute Resolution Panel (DRP) vide DIN & Order No. ITBA/DRP/F/144C(5)/2024- 25/1071299337 (1) dated 17.12.2024 passed u/s. 144C(5) of the Income-tax Act, 1961 (hereinafter referred

Kaushal Ganpatbhai Patel, Ahmedabad vs. The ITO, Ward-1(Intl. Taxation), Ahmedabad

Appeal of the assessee is allowed

ITA 434/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2019-20

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Shri Dhinal Shah, ARFor Respondent: 04.02.2026

Section 147Section 5Section 5(2)(a)Section 6

present appeal has been filed by the assessee against the order passed by the Assessing Officer in accordance with the direction of the Dispute Resolution Panel (“DRP”) under Section 147 r.w.s. 144C(13) of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) order dated 03.12.2024 and relates ... facts and in the circumstances of the case and in law, the learned Assessing Officer ("AO")/Hon'ble Dispute Resolution Panel ("DRP") has erred in making an addition towards the salary income of Rs. 44,24,000 received by the appellant in his bank account with Indian Branch inasmuch

Abdurrehman Shamsulhaq Bapu, Mumbai vs. ITO Ward 1(2)(1), Mumbai

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

ITA 4479/MUM/2025[2016-17]Status: DisposedITAT Mumbai09 Feb 2026AY 2016-17

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2016-17

For Appellant: Shri Vimal Punmiya, CAFor Respondent: Shri Satya Pal Kumar, CIT DR

Section 144C(2)Section 144C(3)Section 147Section 148Section 250Section 56(2)(vii)Section 69

order u/s.144C(2) was passed on 04.03.2022 requesting the assessee to file either acceptance of this order or file objections of variations with Dispute Resolution Panel under intimation to the Assessing Officer within thirty days of receipt of the draft order. Since the assessee only filed his Return of income

Booking.Com B.V., the Netherlands vs. Assistant Commissioner of Income-Tax, Circle 1(1)(2), International Taxation, Delhi

In the result, the appeal of the assessee is allowed

ITA 2033/DEL/2025[2018-19]Status: DisposedITAT Delhi06 Feb 2026AY 2018-19

Bench: Shri M Balaganesh & Shri Vimal Kumarbooking.Com B.V. Vs. Acit, Circle -1(1)(2) Oosterdokskade 163, International Taxation, 1011 Dl, Amsterdam, The Civic Centre, Minto Road, Netherlands, New Delhi – 110002 Haryana 122002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aagcb2395A Appellant .. Respondent

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. M.S. Nethrapal, CIT, DR

Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 149(1)(b)Section 151

following grounds: “1. That on the facts and the circumstances of the case and in law, the Ld. AO and the Ld. Dispute Resolution Panel ('DRP') have erred in holding that the Appellant's income amounting to INR 396,09,81,782 is chargeable to tax in India. 2. That

Zs Associates India Pvt.Ltd, Pune vs. Deputy Commissioner of Income-Tax, Circle -12, Pune

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

ITA 211/PUN/2022[2017-18]Status: DisposedITAT Pune05 Feb 2026AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.211/Pun/2022 निर्धारण वषा / Assessment Year: 2017-18 Zs Associates India Private V The Additional / Joint / Limited, S Deputy / Assistant Tower 3, World Trade Centre, Commissioner Of Kharadi, Pune – 411014. Income Tax, Dcit, Circle-12, Pune. Pan:Aaacz2157Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Ninad Patade (Through Virtual) Revenue By Shri Prakash L Pathade Date Of Hearing 11/12/2025 Date Of Pronouncement 06/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Assessee Has Filed An Appeal Against The Assessment Order Dated 16.02.2022 Passed U/S.143(3) R.W.S 144C(13) Read With Section 144B Of The Act, 1961 For The A.Y.2017- 18, Emanating From Order Of The Dispute Resolution Panel U/S.144C(5) Of The Act, Dated 06.12.2021, Which In Turn Emanates From Draft Assessment Order U/S.143(3) R.W.S 144C(1) Of The Act

Section 143(3)Section 144Section 144BSection 144C(5)

passed u/s.143(3) r.w.s 144C(13) read with section 144B of the Act, 1961 for the A.Y.2017- 18, emanating from order of the Dispute Resolution Panel u/s.144C(5) of the Act, dated 06.12.2021, which in turn emanates from Draft Assessment Order u/s.143(3) r.w.s 144C ... case and in law, the learned AO or Transfer Pricing Officer (hereinafter referred to as "TPO") pursuant to the directions of Hon'ble Dispute Resolution Panel (hereinafter referred to as "DRP"), has erred in making an adjustment amounting to INR 52,79,57,627/-to the value of international transactions

Ba Continuum India Private Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

ITA 368/HYD/2024[2005-06]Status: DisposedITAT Hyderabad04 Feb 2026AY 2005-06

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 10ASection 142(1)Section 143(2)Section 147Section 40

file an appeal before the CIT(A) against the purported additions/disallowances to its returned income and did not wish to approach the Dispute Resolution Panel (DRP) for dispute resolution. 8. In the meantime, on a reference made by the AO to the Additional Commissioner of Income Tax (Transfer Pricing), Hyderabad