“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, Swargate Pune vs. Cummins India Ltd, Pune

In the result, appeal of the assessee bearing ITA No

ITA 1256/PUN/2023[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Ms. Astha Chandra

Section 10ASection 115JSection 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 35

vide order dated 03/09/2021. 5. Against the draft assessment order passed by the Faceless Assessing Officer, assessee filed objections before Ld. Dispute Resolution Panel (DRP), who after considering the submissions of the assessee, passed the order u/s.144C(5) of the Act on 18/05/2022 giving various directions. Ld.AO thereafter, passed ... National Faceless Assessment Centre, Delhi (hereinafter referred to as "Assessing Officer /"AO") in pursuance of the directions issued by the Hon'ble Dispute Resolution Panel - 3, Mumbai ["hereinafter referred to as "DRP"] on the following grounds, which are independent of and without prejudice to each other : General ground: 1 Ground

Cummins India Limited, Pune vs. Assistant Commissioner of Income-Tax, Circle - 1(1), Pune

In the result, appeal of the assessee bearing ITA No

ITA 632/PUN/2022[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Ms. Astha Chandra

For Appellant: Shri J.D. Mistri, Sr. Advocate &For Respondent: Shri Prakash L. Pathade, CIT-DR

Section 10ASection 13Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 80J

vide order dated 03/09/2021. 5. Against the draft assessment order passed by the Faceless Assessing Officer, assessee filed objections before Ld. Dispute Resolution Panel (DRP), who after considering the submissions of the assessee, passed the order u/s. 144C(5) of the Act on 18/05/2022 giving various directions. Ld.AO thereafter, passed ... National Faceless Assessment Centre, Delhi (hereinafter referred to as "Assessing Officer /"AO") in pursuance of the directions issued by the Hon'ble Dispute Resolution Panel - 3, Mumbai ["hereinafter referred to as "DRP"] on the following grounds, which are independent of and without prejudice to each other : ITA Nos.632/PUN

Netcracker Technology Solutions (India) Private Limited, Hyderabad vs. DCIT., Circle - 5(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 730/HYD/2024[AY 2020-21]Status: DisposedITAT Hyderabad03 Dec 2025

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

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

short “the Act”), dated 06.06.2024, 2 NetCracker Technology Solutions (India) Private Limited, in pursuance to the Directions dated 29.05.2024 of the learned Dispute Resolution Panel–1 (“DRP”), Bengaluru, passed under Section 144C(5) of the Act, pertaining to the assessment year 2020-21. 2. The grounds raised by the assessee ... Assessing Officer ie, the Assessment Unit, Income Tax Department (hereinafter referred to as 'the Ld. AO') under the directions issued by the Honourable Dispute Resolution Panel ('the Hon'ble DRP'), erred in making transfer pricing adjustment of INR 4,56,91,941 towards interest on outstanding receivables

Brightcom Group Limited (Formerly Known As Lycos Internet Limited), Hyderabad vs. Asst. Commissioner of Income Tax, Circle-16(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 1862/HYD/2017[2013-14]Status: DisposedITAT Hyderabad03 Dec 2025AY 2013-14

Section 145Section 92BSection 92C

book profit u/s 115JB of Rs. 10,57,25,727/-. 6. Aggrieved by the draft assessment order, assessee has filed objections before Dispute Resolution Panel (DRP) on 27.01.2017. Considering the objections of the assessee, Hon'ble DRP has issued direction vide order dated 04.09.2017 making suitable adjustments ... रधजस्व/ The Revenue : The Assistant Commissioner of Income Tax, Circle 16(1), Hyderabad. 3. The Principal Commissioner of Income Tax, Hyderabad. 4. Dispute Resolution Panel – 1, Bengaluru 5. The Director of Income Tax (IT & TP), Hyderabad. नवभधगीयप्रनतनिनर्, आयकर अपीलीय अनर्करण, हैदरधबधद / DR, ITAT, Hyderabad 6. 7. गधर्ाफ़धईल / Guard file आदेशधिुसधर

Iqvia Ag, Switzerland vs. The Deputy Commissioner of Income Tax (Internaltional Taxation) - 2(2)(2), Mumbai

In the result, the appeal filed by the assessee is allowed in above terms

ITA 4549/MUM/2023[2021-22]Status: DisposedITAT Mumbai02 Dec 2025AY 2021-22

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhan

Section 142(1)Section 143(2)Section 144C(5)Section 90(2)

Treaty (‘Tax Treaty') 1. On the facts and in the circumstances of the case and in law, the Ld. Assessing Officer (AO) / Dispute Resolution Panel (DRP) erred in concluding that the Subscription Income received by the Appellant for providing access to its online database of statistically compiled pharmaceutical data collected ... Indo-Swiss DTAA. The assessing officer also stated that in the assessment proceedings for assessment year 2013-14 to 2015-16 the Dispute Resolution Panel has upheld the order of the assessing officer and held that subscription income received by the company is in the nature of royalty

Iqvia Ag, Switzerland vs. The Income Tax Officer (International Taxation) - 2(2)(1), Mumbai

In the result, the appeal filed by the assessee is allowed in above terms

ITA 3359/MUM/2023[2020-21]Status: DisposedITAT Mumbai02 Dec 2025AY 2020-21

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhan

Section 142(1)Section 143(2)Section 144C(5)Section 90(2)

Balaji Powertronics, New Delhi vs. DCIT, Circle- 43(1), New Delhi

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

ITA 2743/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Dec 2025AY 2017-18

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2017-18 M/S. Balaji Powertronics, Vs. Dcit, Circle-43(1), H-56, Udyog Nagar, New Delhi Main Rohtak Road, Delhi – 1100 41 Pan :Aagfb0501M (Appellant) (Respondent)

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 270ASection 80Section 928A

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘H’ NEW DELHI BEFORE SHRI M BALAGANESH, ACCOUNTANT MEMBER AND SHRI VIMAL

Matrix Clothing Private Limited, Gurgaon vs. ACIT-CC-18, Delhi

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

ITA 3805/DEL/2024[2020-21]Status: DisposedITAT Delhi01 Dec 2025AY 2020-21

Bench: Shri M. Balaganesh & Shri Vimal Kumarmatrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B Assessee By : Ms. Kavita Jha, Sr. Adv Shri Himanshu Agarwal, Adv Shri Akash Shukla, Adv Revenue By: Shri Chetan P. S. Rao, Cit Dr Date Of Hearing 02/09/2025 Date Of Pronouncement 01/12/2025 Matrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B

For Appellant: Ms. Kavita Jha, Sr. AdvFor Respondent: Shri Chetan P. S. Rao, CIT DR

Section 133(6)Section 143(3)Section 144C(5)Section 92C

section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (for short ‘the Act’) inconsonance with the order passed by the Dispute Resolution Panel (DRP) dated 03.01.2022 u/s 144C(5) and TPO order dated 29.01.2021 passed u/s 92CA(3). 2. The Ground No. 1 raised by the assessee ... section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (for short ‘the Act’) inconsonance with the order passed by the Dispute Resolution Panel (DRP) dated 29.052024 u/s 144C(5). 24. The Ground Nos. 1 to 4 raised by the assessee are general in nature and does

Matrix Clothing Private Limited, Gurgaon vs. ACIT, Central Circle-18, Delhi

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

ITA 760/DEL/2022[2017-18]Status: DisposedITAT Delhi01 Dec 2025AY 2017-18

For Appellant: Ms. Kavita Jha, Sr. AdvFor Respondent: Shri Chetan P. S. Rao, CIT DR

Section 133(6)Section 143(3)Section 144C(5)Section 92C

Anurodh Sahu, Jabalpur vs. ITO (It and Tp), Bhopal

In the result, the appeal is allowed for statistical purposes

ITA 11/JAB/2024[2018-19]Status: DisposedITAT Jabalpur28 Nov 2025AY 2018-19

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2018-19 Anurodh Sahu, Vs. Ito (Ft & Tp), 3173, Tulsi Nagar Ranjhi, Jabalpur, Bhopal Madhya Pradesh Pan: Bktps9371L (Appellant) (Respondent) Assessee By: Sh. Anil Agrawal, C.A. Revenue By: Sh. Alok Bhura, Sr. Dr Date Of Hearing: 17.09.2025 Date Of Pronouncement: 28.11.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Income Tax Officer (It & Tp), Bhopal At Jabalpur Dated 16.01.2024 Under Section 147 R.W.S. 144C(13) Of The Income Tax Act For The A.Y. 2018-19. The Grounds Of Appeal Are As Under: - “1. That The Assessment Order Issued By The Learned Assessing Officer On The Basis Of Directions Of Drp Is Unjustified & Base Less On The Basis Of Information & Documents Submitted. 2. That The Learned Assessing Officer Has Never Countered Or Produced Before The Assessee The Source Of Information/ Documents On Basis Of Which The Said Addition Appealed Against Is Made During Whole Assessment Proceedings. 3. That The Learned Assessing Officer Never Questioned The Relevant Sources Of Income Produced & Submitted By The Assessee During The Assessment Proceedings & Brought Nothing On Record To Prove Or Justify The Assessee Having Some Other Source Or Hidden Source Of Income. 4. That The Learned Assessing Officer Has Made The Additions On The Basis Of Incomplete Information Having No Evidence & Based On Surmises On The Directions Given By Drp.

For Appellant: Sh. Anil Agrawal, C.AFor Respondent: Sh. Alok Bhura, Sr. DR

Section 147Section 148Section 271

this draft assessment order to the assessee and advised the assessee to either file his acceptance or prefer an appeal before the Dispute Resolution Panel. 3. The assessee filed an objection before the Dispute Resolution Panel (DRP). Before the DRP, it was submitted that no such quantum of transaction

Assistant Commissioner of Income-Tax, Pune vs. M/S. Visteon Engg. Centre (I) Pvt. Ltd., Pune

In the result, appeal filed by the Revenue is dismissed

ITA 625/PUN/2016[2011-12]Status: DisposedITAT Pune28 Nov 2025AY 2011-12

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.625/Pun/2016 Assessment Year : 2011-12

For Appellant: Shri Amit BobdeFor Respondent: Shri Paras S. Savla

Section 10ASection 143(3)

setting off unabsorbed depreciation and brought forward losses.” 4. At the outset, ld. Counsel for the assessee submitted that the finding of Ld. Dispute Resolution Panel (DRP) deserves to be affirmed in view of plethora of judgements including the judgment of Hon’ble Apex Court in the case

Microsoft Research Lab India Private Limited, Bengaluru vs. Deputy Commissioner of Income-Tax, Circle 4(1)(1), Bengaluru

In the result, the appeal is set aside for doing it denovo

ITA 1842/BANG/2024[AY 2017-18]Status: DisposedITAT Bangalore28 Nov 2025

Bench: Ms. Padmavathy S. & Shri Rahul Chaudhary

For Appellant: Sri Nageshwar RaoFor Respondent: Dr. Divya K.J

Section 143(3)Section 144BSection 144CSection 144C(2)Section 144C(3)Section 153Section 153BSection 250

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. (3) The Assessing Officer shall complete the assessment on the basis of the draft order, if (a) the assessee

Marvell India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-4(1)(1), Bengaluru

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

ITA 1608/BANG/2024[2020-21]Status: DisposedITAT Bangalore28 Nov 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Rahul Chaudharym/S. Marvell India Private Limited 10Th Floor, Tower D & E Global Technology Park, Marathahalli Outer Ring Road Devarabeesanahalli Village Varthurhobli Bangalore 560 103 ………. Appellant [Pan: Aaecm5559R]

For Appellant: Sri Chavali NarayanFor Respondent: Sri Muthu Shankar

Section 143(3)Section 144C(1)Section 144C(13)Section 200ASection 234ASection 234BSection 234CSection 270ASection 274Section 28

read with Section 144C(13) of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’] as per the direction of the Dispute Resolution Panel -2, Bengaluru [hereinafter referred to as ‘DRP’] issued vide Order, dated 29/05/2024 for the Assessment Year 2020-2021. Assessment Year

Devindra Singh, Jhajjar vs. DCIT, Int. Tax, Gurgaon

In the result, impugned assessment order is quashed being without jurisdiction and appeal of the assessee is allowed

ITA 4715/DEL/2025[2015-16]Status: DisposedITAT Delhi28 Nov 2025AY 2015-16

Bench: Shri Vikas Awasthy& Shri M. Balaganeshआअसं.4715/िद"ी/2025(िन.व. 2015-16) Devindra Singh, Viilage Naya Gaon, Bahadurgarh, Jhajjar, Haryana 124507 ...... अपीलाथ"/Appellant Pan No: Akppg-1164-L बनाम Vs. Deputy/Assistant Commissioner Of Income Tax, ....."ितवादी/Respondent International Taxation, Gurgaon, Haryana

For Appellant: S/Shri Pranshu Singhal, Chartered Accountants &For Respondent: Shri M.S Nethrapal, CIT-DR

Section 143(1)Section 144CSection 147Section 148Section 148ASection 68

Assessing Officer (AO) passed the Draft Assessment Order dated 22.03.2024 making addition of Rs.52,40,000/-. The assessee filed objections before the Dispute Resolution Panel (DRP) inter alia objecting to initiation of proceeding u/s. 148 of the Act beyond three years, even, though the amount was less than Rs.50 ... After directions of the DRP, the AO examined the issue and concluded as under:- “Pursuant to the directions issued by the Hon'ble Dispute Resolution Panel (DRP), the addition of Rs.17,11,500/- is hereby deleted. Consequently, the impact of this deletion will be duly incorporated while computing the taxable

Thaicom Public Company Ltd, Delhi vs. ACIT, Central Circle Intl Tax-3(1)(1), Delhi

In the result, impugned order is quashed and appeal of the assessee is allowed

ITA 1803/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Nov 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं.1803/िद"ी/2025(िन.व. 2018-19) Thaicom Public Company Ltd., (Earlier Known As Shin Satellite Public Company Ltd.), C/O Mohinder Puri & Co. 1A-D, Vandhna, 11 Tolstoy Marg, New Delhi 110001 ...... अपीलाथ"/Appellant Pan No: Aagcs-4481-E बनाम Vs. Assistant Commissioner Of Income Tax, Circle 3(1)(1), International Taxation, ..... "ितवादी/Respondent New Delhi 11002

For Appellant: Shri Ajay Vohra, Sr. Advocate with S/Shri Jatinder Singh & Akshay MathurFor Respondent: Shri M.S Nethrapal, CIT-DR (Through VC)

Section 143(3)Section 147Section 148ASection 9(1)(vi)

Gujarat High Court on 31.03.2014. 4. Per Contra, Shri M.S Nethrapal representing the department strongly supported findings of the AO and the Dispute Resolution Panel (DRP) on the issue of validity of reopening of assessment. The ld. DR submits that no assessment u/s.143(3) of the Act was made

Epam Systems India Private Limited, Hyderabad vs. DCIT, Circle -8 (1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 83/HYD/2022[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: CA Shreyas SardesaiFor Respondent: MS U Mini Chandran, CIT-DR

Section 143(3)

international transaction relating to Software development segment 1:1 The learned Assessing Officer ("AO")/ Transfer Pricing Officer ("TPO")/ Dispute Resolution Panel ("DRP") has erred in making an upward adjustment of INR 16,86,23,336/- to the total income of the Appellant by holding that the international transaction relating ... case and in law, the learned Transfer Pricing Officer ('TPO') and the learned Assessing Officer ('AO'), under directions of the Hon'ble Dispute Resolution Panel ('DRP'), have erred in making an addition of Rs. 9,60,77,283/- to the total income of the Appellant by holding that the international

Epam Systems India Private Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 498/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

For Appellant: CA Shreyas SardesaiFor Respondent: MS U Mini Chandran, CIT-DR

Section 143(3)

Repal Renewables Private Limited, Hyderabad vs. DCIT Circle -3(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 481/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.116 & 481/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Repal Renewables Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aagcr9762B (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR

Section 115JSection 143(3)Section 153Section 234Section 234BSection 234DSection 270A

facts and circumstances of the case and in law, the Id. AO and the Ld. TPO, under the directions of the Hon'ble Dispute Resolution Panel ('DRP'), erred in re-characterizing the transaction of 'Payment of interest towards purchase on supplier credit' as an external commercial borrowing and thereby calculating ... quashed in- limine as the same is without jurisdiction because it has been passed without following the mandatory directions of the Hon'ble Dispute Resolution Panel ('DRP'). Payment of interest towards purchase on supplier credit 3. On the facts and circumstances of the case

Repal Green Power Private Limited, Hyderabad vs. DCIT Circle -3(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 474/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.125/Hyd/2022 Assessment Year 2017-2018 Repal Green Power Private Limited, The Dcit, Circle-8(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aahcr2187F (Appellant) (Respondent) आ.अपी.सं /Ita No.474/Hyd/2022 Assessment Year 2018-2019 Repal Green Power Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aahcr2187F (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR

Section 143(3)Section 234Section 234DSection 270ASection 32Section 32A

Dodla Dairy Limited, Hyderabad vs. DCIT Circle -8(1), Hyderabad

ITA 466/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Us:

For Appellant: Shri Aashik Shah, C.AFor Respondent: Ms. U. Mini Chandran

Section 143(3)Section 144Section 80Section 801BSection 80J

circumstances of the case and in law, the final assessment order passed by Ld. Assessing officer ('Ld. AO') pursuant to directions of the Dispute Resolution Panel ('Ld. Panel) under Section 143(3) read with Sections 144C(13) of the Act to the extent prejudicial to the Appellant ... company at a discounted rate of interest to its director: Rs.2,50,000/- 8. The assessee objected to the proposed adjustments before the Dispute Resolution Panel–1, Bangalore (for short, “DRP”). However, the DRP found no infirmity in the view taken by the A.O./TPO, and upheld the declining