“dispute resolution panel”

Telstra Singapore Pte Ltd, Singapore vs. Deputy Commissioner of Income Tax, Circle 3(1)(1), International Taxation, Delhi

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

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2022-23 Telstra Singapore Pte Ltd., Vs. Dcit, Circle-3(1)(1), 8 Cross Street, 22-00, Manulife International Taxation, Tower, Singapore New Delhi Pan :Aadct5366N (Appellant) (Respondent)

Income Tax, Circle-3(1)(1) International Taxation, New Delhi ('the Id. AO') in pursuance of the directions of the Hon'ble Dispute Resolution Panel -2 (Hon'ble DRP) is wrong and bad in law, contrary to facts and circumstances of the case and unsustainable in law. 2. Based

Srf Limited, Delhi vs. Assistant / Deputy Commissioner of Income Tax, Circle 10(1), New Delhi, Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

r.w.s. 260 of the Income-tax Act, 1961 (for short ‘the Act”) for Assessment Years 2017-18 pursuant to the directions of the Dispute Resolution Panel u/s 144C(5) of the Act. 2. Since the issues are common and the appeals are connected, hence the same are heard together ... final assessment order u/s 143(3) r.w.s. 260 of the Act dated 29th April, 2022 pursuant to the directions of the Learned Dispute Resolution Panel (‘Ld. DRP’) dated 09th February, 2022 making transfer pricing adjustments / additions of Rs. 56,31,05,314/- arising out of the order

Swatch Group (India) Retail Private Limited, Delhi vs. The Deputy Commissioner of Income Tax, Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

Bench: Shri S.Rifaur Rahman & Ms. Madhumita Royswatch Group (India) Retail Private Ltd., Vs. Dcit, Circle 22(2), 4Th Floor, Rectangle 1, Plot No.D4, Delhi. Saket District Centre, Saket, New Delhi – 110 017. (Pan : Aavcs7960H) (Appellant) (Respondent) Assessee By : Shri Ravi Sharma, Advocate Ms. Shruti Khimta, Ar Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 16.09.2025 Date Of Order : 12.12.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 26.07.2024 Passed By The Assessment Unit, Income Tax Department Under Section 143(3) Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :-

r.w.s. 144B of the Income-tax Act, 1961 (for short ‘the Act”) for Assessment Year 2020-21 pursuant to the directions of the Dispute Resolution Panel u/s 144C(5) of the Act raising following grounds of appeal :- 2 “1. On the facts and circumstances of the case

Tata Steel Limited (Successor of Angul Energy Limited), Delhi vs. Assistant Commissioner of Income-Tax, New Delhi

In the result, assessee’s appeal in ITA No

Bench: Ms. Madhumita Roy & Smt. Renu Jauhriassessment Year: 2020-21

r.w.s. 144C(13) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), pursuant to the directions of the Learned 2 Dispute Resolution Panel (“DRP”) under Section 144C(5) of the Act for the Assessment Year 2022-23. 2. Grounds of appeal raised by the assessee ... Learned AO upheld the TP adjustment in the draft assessment order dated 28.09.2023. Against the same the Assessee filed objections before the Learned Dispute Resolution Panel ('DRP'), wherein the assessee reiterated that the rate of interest charged by TSBSL from the Assessee was determined based on MCLR, which is currently

Srf Limited, Delhi vs. ACIT, Circle-10(1), Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

r.w.s. 260 of the Income-tax Act, 1961 (for short ‘the Act”) for Assessment Years 2017-18 pursuant to the directions of the Dispute Resolution Panel u/s 144C(5) of the Act. 2. Since the issues are common and the appeals are connected, hence the same are heard together ... final assessment order u/s 143(3) r.w.s. 260 of the Act dated 29th April, 2022 pursuant to the directions of the Learned Dispute Resolution Panel (‘Ld. DRP’) dated 09th February, 2022 making transfer pricing adjustments / additions of Rs. 56,31,05,314/- arising out of the order

Srf Limited, New Delhi vs. ACIT, Circle-10(1), Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

r.w.s. 260 of the Income-tax Act, 1961 (for short ‘the Act”) for Assessment Years 2017-18 pursuant to the directions of the Dispute Resolution Panel u/s 144C(5) of the Act. 2. Since the issues are common and the appeals are connected, hence the same are heard together ... final assessment order u/s 143(3) r.w.s. 260 of the Act dated 29th April, 2022 pursuant to the directions of the Learned Dispute Resolution Panel (‘Ld. DRP’) dated 09th February, 2022 making transfer pricing adjustments / additions of Rs. 56,31,05,314/- arising out of the order

Cosmo Films Ltd., New Delhi vs. DCIT, Circle- 6(2), New Delhi

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

Bench: Shri S.Rifaur Rahman & Ms. Madhumita Roycosmo Films Limited, Vs. Dcit, Circle 6 (2), 1008, Dlf Tower A, New Delhi. Jasola District Centre, New Delhi – 110 025. (Pan : Aaacc1152C) (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Advocate Shri Somil Aggarwal, Advocate Shri Deepesh Garg, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 18.09.2025 Date Of Order : 12.12.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 27.10.2013 Passed By The Dcit, Circle 6 (2), Delhi Under Section 143(3) Read With Section 144C Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2013-14 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :-

section 144C of the Income-tax Act, 1961 (for short ‘the Act”) for Assessment Year 2013-14 pursuant to the directions of the Dispute Resolution Panel u/s 144C(5) of the Act raising following grounds of appeal :- 2 “1. That the Learned Deputy Commissioner of Income tax, Circle ... r.w.s 144C of the Act as against the returned income of INR 9,11,89,260. 2. That the Ld. AO/ Dispute Resolution Panel (hereinafter referred to as “Ld. DRP”) erred on facts and in law in confirming an adjustment amounting to INR 6,014,935/- on account of notional

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

In the result, the appeal being ITA No

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareek

Income-tax Act, 1961 (for short ‘the Act”) for Assessment Years 2011-12 & 2013-14 respectively pursuant to the directions of the Dispute Resolution Panel u/s 144C(5) of the Act. 2. Since the issues are common and the appeals are connected, hence the same are heard together and being ... Officer, however, did not entertain the revised claim on the ground that it was not made in the original return of income. The Dispute Resolution Panel, while upholding the Assessing Officer’s view, placed reliance on the decision of the Hon’ble Supreme Court in Goetze (India

Srf Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal being ITA No

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareek

Income-tax Act, 1961 (for short ‘the Act”) for Assessment Years 2011-12 & 2013-14 respectively pursuant to the directions of the Dispute Resolution Panel u/s 144C(5) of the Act. 2. Since the issues are common and the appeals are connected, hence the same are heard together and being ... Officer, however, did not entertain the revised claim on the ground that it was not made in the original return of income. The Dispute Resolution Panel, while upholding the Assessing Officer’s view, placed reliance on the decision of the Hon’ble Supreme Court in Goetze (India