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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

Rockwell Automation India Private Limited, Delhi vs. DCIT Circle-19(1), Delhi

Appeal is partly allowed for statistical purposes

ITA 3861/DEL/2024[2020-21]Status: DisposedITAT Delhi17 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalrockwell Automation India Deputy Commissioner Of Private Limited, Income Tax, Circle-19(1), Registered Address: 131, Vs. Delhi. Functional Industrial Are, Patparganj, Delhi-110092 Communication Address: 131, Functional Industrial Area, Patparganj, New Delhi. Pan-Aaccr3791A (Appellant) (Respondent) Assessee By Shri Ajit Jain, Ar Department By Shri Dharm Veer Singh, Cit-Dr Date Of Hearing 19.08.2025 Date Of Pronouncement 17.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Final Assessment Order Passed U/S 143(3) R.W.S 144C (13) Read With Section 144B Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) Dated 30.07.2024 For Assessment Year 2020-21. 2. Brief Facts Of The Case Ae That The Assessee Is A Company Engaged In The Business Of Manufacturing / Assembling Of Automation & Industrial Control Products / Systems. The Case Was Selected For Scrutiny & A Reference Was Made To The Tpo Due With Transactions With Ae’S. The Return Of Income Was Filed On Rockwell Automation India Private Limited Vs. Dcit 15.02.2021 Declaring Total Income At Rs.97,08,46,360/-. The Tpo Vide Its Order Dated 28.07.2023 Passed U/S 92Ca(3) Of The Act Has Proposed Adjustments Totaling To Rs. 26,12,44,668/-. Thereafter, The Ao Has Passed The Draft Assessment Order U/S 144C(1) Of The Act Dated 27.09.2023 Wherein The Ao Has Proposed The Additions Towards The Tp Adjustment As Per Tpo’S Order & Proposed To Assess The Total Income Of The Assessee At Rs.19,88,57,458/- & Further Proposed To Disallow Relief Claimed U/S 90/90A At Rs.1,04,60,287/-. Against The Draft Assessment Order, The Assessee Filed Objections Before The Drp.

Section 143(3)Section 144BSection 144C(1)Section 144C(10)Section 144C(13)Section 144C(8)Section 90Section 90ASection 92C

Tribunal by raising the following grounds of appeal: “Pertaining to Transfer Pricing matters 1. On the facts and in law, the Honourable Dispute Resolution Panel ('Hon'ble DRP'), the Learned Transfer Pricing Officer (Ld. TPO) and the Ld. AO (hereinafter collectively to be referred as "Revenue") erred in making