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“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

Repal Green Power Private Limited, Hyderabad vs. DCIT, Circle 8(1), Hyderabad

ITA 125/HYD/2022[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.125/Hyd/2022

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)Section 234Section 234DSection 270ASection 32Section 32A

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 Renewables Private Limited, Hyderabad vs. DCIT, Circle 8(1), Hyderabad

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

ITA 116/HYD/2022[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

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

Ceb Llc (Earlier Known As Ceb Inc.), United States of America vs. Assistant Commissioner of Income Tax, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2025/DEL/2025[2018-19]Status: DisposedITAT Delhi26 Nov 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2018-19] Ceb Llc (Earlier Known As The Assistant Commissioner Ceb Inc.), 1201, Wildson Of Income Tax, Blvd. Arlington, Va 22209, Vs Circle- 1(2)(1), International United States Taxation E-2 Block, Civic Care Of Address Centre, Minto Road, New First International Financial Delhi-110002. Centre, Level-2 Plot No. C-54 & 55, G Block, Bandra Kurla Complex, Bandra East, Mumbai-400051, Maharashtra, India. Pan- Aadct5119K Assessee Revenue

Section 144Section 147Section 148Section 148ASection 153(1)Section 9(1)(vi)

Assessing Officer dated 31.01.2025 passed u/s 147/144 of the Income Tax Act, 1961 (hereinafter ‘the Act’) arising out of the direction of Dispute Resolution Panel date of directions 10.12.2024 pertaining to Assessment Year 2018-19. 1.1. The grounds of appeal raised by the assessee reads as under:- “1. That

Alstom Transport Sa, Karnataka vs. DCIT, Int. Taxation Circle 1(1)(1), Delhi

In the result, impugned assessment order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 1715/DEL/2025[2022-23]Status: DisposedITAT Delhi26 Nov 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.1711 To 1715/िद"ी/2025(िन.व. 2011-12, 2013-14 To 2015-16 और 2022-23)

For Appellant: Shri Deepak Chopra & Ms. Priyan TandonFor Respondent: Shri Nikhil Kumar Govila, CIT(DR)

year i.e. AY 2010-11 and in the subsequent assessment years starting from AY 2018-19 to 2020-21, the AO and the Dispute Resolution Panel (DRP) have held that the assessee was having PE. There has been no change in the facts and the contracts in the impugned assessment

Alstom Transport Sa, Karnataka vs. DCIT, Int. Taxation Circle 1(1)(1), Delhi

In the result, impugned assessment order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 1714/DEL/2025[2015-16]Status: DisposedITAT Delhi26 Nov 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.1711 To 1715/िद"ी/2025(िन.व. 2011-12, 2013-14 To 2015-16 और 2022-23)

For Appellant: Shri Deepak Chopra & Ms. Priyan TandonFor Respondent: Shri Nikhil Kumar Govila, CIT(DR)

year i.e. AY 2010-11 and in the subsequent assessment years starting from AY 2018-19 to 2020-21, the AO and the Dispute Resolution Panel (DRP) have held that the assessee was having PE. There has been no change in the facts and the contracts in the impugned assessment

Alstom Transport Sa, Bangalore vs. DCIT Intl. Taxation Circle 1(1)(1), New Delhi

In the result, impugned assessment order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 1713/DEL/2025[2014-15]Status: DisposedITAT Delhi26 Nov 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.1711 To 1715/िद"ी/2025(िन.व. 2011-12, 2013-14 To 2015-16 और 2022-23)

For Appellant: Shri Deepak Chopra & Ms. Priyan TandonFor Respondent: Shri Nikhil Kumar Govila, CIT(DR)

year i.e. AY 2010-11 and in the subsequent assessment years starting from AY 2018-19 to 2020-21, the AO and the Dispute Resolution Panel (DRP) have held that the assessee was having PE. There has been no change in the facts and the contracts in the impugned assessment

Alstom Transport Sa, Bangalore vs. DCIT Intl. Taxation Circle 1(1)(1), New Delhi

In the result, impugned assessment order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 1712/DEL/2025[2013-14]Status: DisposedITAT Delhi26 Nov 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.1711 To 1715/िद"ी/2025(िन.व. 2011-12, 2013-14 To 2015-16 और 2022-23)

For Appellant: Shri Deepak Chopra & Ms. Priyan TandonFor Respondent: Shri Nikhil Kumar Govila, CIT(DR)

year i.e. AY 2010-11 and in the subsequent assessment years starting from AY 2018-19 to 2020-21, the AO and the Dispute Resolution Panel (DRP) have held that the assessee was having PE. There has been no change in the facts and the contracts in the impugned assessment

Alstom Transport Sa, Karnataka vs. DCIT International Taxation, Circle 1(1)(1), New Delhi

In the result, impugned assessment order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 1711/DEL/2025[2011-12]Status: DisposedITAT Delhi26 Nov 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.1711 To 1715/िद"ी/2025(िन.व. 2011-12, 2013-14 To 2015-16 और 2022-23)

For Appellant: Shri Deepak Chopra & Ms. Priyan TandonFor Respondent: Shri Nikhil Kumar Govila, CIT(DR)

year i.e. AY 2010-11 and in the subsequent assessment years starting from AY 2018-19 to 2020-21, the AO and the Dispute Resolution Panel (DRP) have held that the assessee was having PE. There has been no change in the facts and the contracts in the impugned assessment

Gbt India Private Limited, New Delhi vs. ACIT, OSD, Delhi

In the result, the assessee’s appeal is allowed as above

ITA 1764/DEL/2022[2018-19]Status: DisposedITAT Delhi26 Nov 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 143(3)Section 234ASection 36(1)(vii)Section 36(2)

Transfer Pricing Adjustment GBT India Pvt. Ltd. 2. That on the fact and circumstances of the case and in law, the Hon'ble Dispute Resolution Panel ("DRP")/Ld. AO/Ld. Transfer Pricing Officer ("TPO") erred in determining the Arm's Length Price ("ALP") of transition support services as NIL, by rejecting ... account of bad debts written off. 3.4 The appellant assessee, raising disputes on the above-mentioned four issues, went before the Dispute Resolution Panel (‘DRP’), but did not succeed. Hence, the final assessment was completed at income of INR 285,039,520/- GBT India Pvt. Ltd. wherein the above-mentioned

Kantar Analytics India Private Limited (Formerly Known As Firefly Market Reserch India Private Limited (Successor of Analytics Quotient Service India Private Limited), Mumbai vs. Assistant Commissioner of Income Tax, Circle 1(3)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 4733/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Nov 2025AY 2020-21

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(3)Section 153Section 270ASection 92CSection 92C(1)

case and in law, the learned Transfer Pricing Officer ("TPO") and the learned Assessing Officer ('AO') under the directions of the Hon'ble Dispute Resolution Panel ('DRP') erred in making an adjustment of Rs.5,52,62,002 (with respect to payment of management charges) under Chapter X of the Income

Florida Retirement System, Mumbai vs. Assistant Commissioner of Income Tax International Taxation -2(3)(1), Mumbai

The appeal stands allowed in the aforesaid terms

ITA 1866/MUM/2025[2022-23]Status: DisposedITAT Mumbai21 Nov 2025AY 2022-23

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115ASection 144Section 144CSection 234Section 234BSection 270ASection 70Section 70(2)

Income-tax Act, 1961 (the Act'), in pursuance of the directions dated & December 2024, issued by the Hon'ble Dispute Resolution Panel-1, Mumbai ('Ld. DRP) on the following grounds, each of which is without prejudice to and independent of the other. On the facts and circumstances of the case ... System credit reflected, the said dividend had to be offered to tax in the return. 5. The assessee carried its objections to the Dispute Resolution Panel. The Panel, by directions dated 5 December 2024, upheld the proposed action of taxing the gross non STT short term capital gains at thirty

Dsv Air & Sea Private Limited, Mumbai vs. ACIT, Cirle-3(1)(1), Mumbai

In the result, this ground of appeal is allowed for statistical purpose

ITA 3653/MUM/2024[2020-21]Status: DisposedITAT Mumbai21 Nov 2025AY 2020-21

Bench: Shri Pawan Singh& Smt.Renu Jauhri(Physical Hearing)

Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 253Section 254(1)Section 92CSection 92C(3)

against the additions made in assessment order passed under section 143(3) r.w.s. 144C(13) dated 31/05/2024, passed in pursuance of direction of Dispute Resolution Panel (DRP) under section 144C(5) dated 27/05/2024. The assessee has raised the following grounds of appeal:- “GROUNDS OF APPEAL Based on the facts ... Mumbai ('learned TPO') in his order passed under Section 92CA(3) of the Act and in pursuance of the Directions issued by Dispute Resolution Panel-1 (DRP- 1) ('Hon'ble DRP"), Mumbai, on the following grounds: On the facts and circumstances of the case and in law, the learned AO/Hon

Lm Wind Power As, Denmark vs. Assistant Commissioner of Income Tax, Circle International Tax 2(2)(1), Delhi

In the result, ground raised by the assessee is allowed

ITA 4280/DEL/2024[2020-21]Status: DisposedITAT Delhi21 Nov 2025AY 2020-21

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Lm Wind Power As, Vs, Acit, Circle Juptervej 6, 6000 Kolding, International Tax 2(2)(1), Denmark – 999999. Delhi (Pan :Aabcl8590Q) (Appellant) (Respondent) Assessee By : Shri Ajay Vohra, Sr. Advocate Shri Aditya Vohra, Advocate Shri Arpitgoyal, Ca Revenue By : Shri Saroj Kumar Dubey, Cit Dr Date Of Hearing : 27.08.2025 Date Of Order : 21.11.2025 Order Per S. Rifaur Rahman: 1. This Appealpreferred By The Assessee Is Directed Against The Assessment Order Dated 27.01.2025 Passed By The Acit, Circle Int. Tax 2(2)(1), Delhi Under Section 143(3) R.W.S. 144C(13) 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 :- “1. That On The Facts & Circumstances Of The Case & In Law, The Assessment Order Dated 29.07.2024 Passed Under Section 143(3) Read With Section 144C(13) Of The Income-Tax Act, 1961 (He Act") For Assessment Year 2020-21 Assessing The Total Income Of The Assessee At Rs.81,14, 14,893 Is Bad In Law, Void- Ab-Initio & Therefore, Liable To Be Quashed And/ Or Set Aside.

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Saroj Kumar Dubey, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 271ASection 44DSection 5Section 92C

144C(13) 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 :- “1. That on the facts and circumstances of the case ... provisions of section 44DA of the Act. 2.3 He submitted that against the above order, the assessee thereafter filed objections before the ld. Dispute Resolution Panel (“DRP”). Pursuant to the directions issued by the DRP under section 144C(5) wherein they sustained the findings of AO/TPO, accordingly, the assessing officer

Gold Spice Impex, Delhi vs. Income Tax Officer, Ward-47(2), Delhi

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

ITA 2244/DEL/2024[2017-18]Status: DisposedITAT Delhi21 Nov 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Vimal Kumarm/S. Gold Spice Impex, Vs. Ito, Ward 47 (2), 1879, Kucha Chelian, Khari Boali, Delhi. Delhi – 110 006. (Pan : Aapfg0688P) (Appellant) (Respondent) Assessee By :Shri Rakesh Gupta, Advocate Shri Deepesh Garg, Advocate Revenue By : Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 26.08.2025 Date Of Order : 21.11.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 17.01.2024 For The Assessment Year 2017-18 Raising Following Grounds Of Appeal :- “1. That Having Regard To The Facts & Circumstances Of The Case, Ld. Cit(A) Has Erred In Law & On Facts In Confirming The Action Of Ld. Ao In Making Aggregate Addition Of Rs.1,15,00,000/- On Account Of Cash Deposits U/S 68 & Taxing The Same U/S 115Bbe & That Too By Recording Incorrect Facts & Findings & Without Following The Principles Of Natural Justice.

For Appellant: Shri Rakesh Gupta, AdvocateFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 115BSection 143(2)Section 234BSection 68

w.e.f. 1.10.1998).][, Commissioner (Appeals)] [Inserted by Act 29 of 1977, Section 39 and Schedule V (w.e.f. 10.7.1978).][, Chief Commissioner or Commissioner and the Dispute Resolution Panel referred to in clause (a) of sub-section (15) of section 144-C] [ Substituted by Act 33 of 2009, Section 50, for " and Chief

Nippon Koei Co. Ltd., Begumpet vs. ADIT (International Taxation)- 2, Hyderabad

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

ITA 670/HYD/2023[2021-22]Status: DisposedITAT Hyderabad20 Nov 2025AY 2021-22

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.670/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2021-22) M/S Nippon Koei Co. Ltd Vs. Adit (International Hyderabad Taxation)-2, Pan:Aabcn8434F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gsv Prasad, Anand Swaroop & S K Mohanty, Cas राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 27/10/2025 घोषणा की तारीख/Pronouncement: 21/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri GSV Prasad, Anand Swaroop and S K Mohanty, CAsFor Respondent: : Smt. U. Mini Chandran, CIT(DR)
Section 143(2)Section 143(3)Section 144CSection 144C(1)Section 144C(13)Section 144C(5)Section 201Section 37(1)Section 40Section 44D

addition of Rs.3,47,02,323/-. 4. Against the draft order of the Ld. AO, the assessee filed its objections before the Learned Dispute Resolution Panel (“Ld. DRP”). The Ld. DRP issued its directions under section 144C(5) of the Act on 28.09.2023. Pursuant thereto, the Ld. AO passed

Swiss Re Asia Pte Ltd, Singapore vs. Deputy Commissioner of Income Tax, (International Taxation) Circle - 4(2)(2), Mumbai

In the result, we hold that the assessee does not have any permanent establishment in India, whether as fixed place

ITA 4092/MUM/2023[2021-22]Status: DisposedITAT Mumbai20 Nov 2025AY 2021-22

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 144CSection 9(1)(i)

Singapore, arise from the final assessment orders passed for assessment years 2020-21 and 2021-22 pursuant to directions of the Dispute Resolution Panel under section 144C of the Income tax Act 1961. In the grounds of appeal assessee has raised various grounds including challenging that the impugned order ... total income at INR 1,211,357,091 as against the returned income of INR 437,500. The assessee raised objections before the Dispute Resolution Panel, which were rejected by following its earlier directions for preceding years. In sum and substance, the reasonings of the AO are as under:- Swiss

Swiss Re Asia Pte Ltd, Singapore vs. Deputy Commissioner of Income Tax, (International Taxation) Circle - 4(2)(2), Mumbai

In the result, we hold that the assessee does not have

ITA 3178/MUM/2023[2020-21]Status: DisposedITAT Mumbai20 Nov 2025AY 2020-21
Section 144CSection 9(1)(i)

Singapore, arise from the final assessment orders passed for assessment years 2020-21 and 2021-22 pursuant to directions of the Dispute Resolution Panel under section 144C of the Income tax Act 1961. In the grounds of appeal assessee has raised various grounds including challenging that the impugned order ... total income at INR 1,211,357,091 as against the returned income of INR 437,500. The assessee raised objections before the Dispute Resolution Panel, which were rejected by following its earlier directions for preceding years. In sum and substance, the reasonings of the AO are as under

Lintas India Private Limited, Mumbai vs. DCIT, Circle 16(1), Mumbai

The appeal of the assessee is partly allowed for statistical purposes

ITA 5889/MUM/2024[2021-22]Status: DisposedITAT Mumbai19 Nov 2025AY 2021-22

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2021-22 M/S. Lintas India Private Assessment Unit, Limited, Income Tax Department Or A Wing, 16Th Floor, Deputy Commissioner Of Parinee Crescenzo, Income Tax, Bandra-Kurla Complex, Circle 16(1), Bandra (East), 1) National Faceless Mumbai – 400 051 Assessment Centre (Nafac), Vs. Pan: Aaacl0124F Delhi 2)Aayakar Bhawan, Maharshi Karve Road, New Marine Lines, Churchgate, Mumbai – 400020 (Appellant) (Respondent) Present For: Assessee By : Shri Ajit Jain, Ld. A.R. Shri Karnik Kansara, Ld. A.R Ms. Neha Rai, Ld. A.R. Ms. Sakshi Chimanani, Ld. A.R. Revenue By : Shri Kiran Unavekar, Ld. Sr. D.R. Date Of Hearing : 22.08.2025 Date Of Pronouncement : 19.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 15.05.2023, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Dispute Resolution Panel-1) (In Short Ld. Commissioner) U/S 144C(5) Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2021-22. 2 M/S. Lintas India Private Limited

For Appellant: Shri Ajit Jain, Ld. A.RFor Respondent: Shri Kiran Unavekar, Ld. Sr. D.R
Section 144Section 144CSection 144C(5)Section 92C

This appeal has been preferred by the Assessee against the order dated 15.05.2023, impugned herein, passed by the Ld. Commissioner of Income Tax (Dispute Resolution Panel-1) (in short Ld. Commissioner) u/s 144C(5) of the Income Tax Act, 1961 (in short ... Lintas India Private Limited 6. The Assessee, being aggrieved, challenged the said draft assessment order by filing the objections before the Ld. Dispute Resolution Panel (in short “Ld. DRP”) u/s 144C of the Act. 7. The Ld. DRP vide order dated 28.08.2024 u/s 144C(5) of the Act while considering

Shell India Markets Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(4), Mumbai

ITA 4828/MUM/2024[2020-21]Status: DisposedITAT Mumbai19 Nov 2025AY 2020-21

Bench: SHRI AMIT SHUKLA, JUDICIAL MEMBER\n&\nMS. PADMAVATHY S (Accountant Member)

Section 143(3)Section 144BSection 144C(1)Section 144C(13)Section 144C(5)Section 270ASection 40Section 92C

read with section 144C(13) and section 144B of the Income-tax Act, 1961, in pursuance of the directions issued by the Dispute Resolution Panel, Mumbai, under section 144C(5) for the assessment year 2020–21. The controversy before us straddles substantial transfer pricing adjustments across multiple business segments ... alleged short deduction of tax at source on a payment of Rs.29,40,517/-. 5. The assessee filed detailed objections before the Dispute Resolution Panel (DRP) on 25 October 2023. After hearing the assessee, the DRP, by directions dated 29 June 2024, substantially upheld the action of the TPO. Pursuant

Inteva Products Netherlands B.V., Netherlands vs. ACIT It Circle 2(1)(1), Delhi

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

ITA 1344/DEL/2025[2022-23]Status: DisposedITAT Delhi19 Nov 2025AY 2022-23

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Inteva Products Netherlands B.V. Vs. Acit, It Circle 2(1)(1), Siriusdreef 17, 2132, Wt, Hoofddorp, Delhi. Netherlands. (Pan :Aadci5208G) (Appellant) (Respondent) Assessee By : Shri Kshitij Bansal, Ca Revenue By : Shri Saroj Kumar Dubey, Cit Dr Date Of Hearing : 28.08.2025 Date Of Order : 19.11.2025 Order Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessee Is Directed Against The Assessment Order Dated 27.01.2025 Passed By The Acit, Circle Int. Tax 2(1)(1), Delhi Under Section 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2022-23Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :- “Ground 1 On The Facts & Circumstances Of The Case & In Law, The Assistant Commissioner Of Income-Tax, Circle International Tax - 2(1)(1), Delhi ('Ld.

For Appellant: Shri Kshitij Bansal, CAFor Respondent: Shri Saroj Kumar Dubey, CIT DR
Section 115ASection 143(3)Section 144C(5)Section 234BSection 270A

144C(13) of the Income-tax Act, 1961 (for short ‘the Act”) for Assessment Year 2022-23pursuant to the directions of the Dispute Resolution Panel u/s 144C(5) of the Act raising following grounds of appeal :- “Ground 1 On the facts and circumstances of the case ... Assistant Commissioner of Income-tax, Circle International Tax - 2(1)(1), Delhi ('Ld. 2 AO) pursuant to the directions of the Dispute Resolution Panel - 1, New Delhi ('Ld. DRP) erred in making an addition of INR 8,28,34,750 and not following the orders of the Co-ordinate Bench