“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

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 505/JPR/2025[2015-16]Status: DisposedITAT Jaipur12 Nov 2025AY 2015-16

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR

Section 144CSection 153CSection 153DSection 250

order bad in law. 10. In this context, reference is invited to provisions of Section 144C of the Act: Section 144C - Reference to dispute resolution panel. (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward a draft of the proposed ... violated by the ld. AO if the draft order was issued then the assessee has remedy to file objection before the Dispute Resolution Panel. 10. On 10.07.2025 the ld. DR submitted that the case of the shows non compliance before the ld. AO and she has not filed the appeal

Precision Camshafts Limited, Pune vs. DCIT Circle 1, Solapur

In the result, appeal of the assessee is partly allowed

ITA 2744/PUN/2024[2021-22]Status: DisposedITAT Pune12 Nov 2025AY 2021-22

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2744/Pun/2024 निर्धारण वषा / Assessment Year: 2021-22 Precision Camshafts Limited, V Assessment Unit, E-102/103, Akkalkot Road S Income Tax Department Midc, Solapur – 413006. (National Faceless Maharashtra. Assessment Center), Jurisdiction : Pne C(1), Range 63, Deputy Commissioner Of Income Tax („Dcit‟), Circle-1, Solapur. Pan: Aabcp1086B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil S Pathak - Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 21/08/2025 Date Of Pronouncement 12/11/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By Assessee Against The Assessment Order Under Section 143(3) R.W.S 144C(13) Read With Section 144B Of The Act, 1961 Dated 24.10.2024 For A.Y.2021-22 Emanating From Dispute Resolution Panel‟S Order Passed Under Section 144C(5) Of

Section 143(3)Section 144BSection 144C(1)Section 144C(5)Section 153Section 92B

Assessment Order under section 143(3) r.w.s 144C(13) read with section 144B of the Act, 1961 dated 24.10.2024 for A.Y.2021-22 emanating from Dispute Resolution Panel‟s order passed under section 144C(5) of ITA No.2744/PUN/2024 [A] the Act, dated 06.09.2024 and Draft Assessment Order passed under section 144C ... Order on 20.12.2023 considering the Transfer Pricing Officer‟s order dated 21.10.2023. Aggrieved by the Draft Assessment Order, Assessee filed its objections before Dispute Resolution Panel(DRP). The DRP vide its order u/s.144C(5) of the Act, dated 06.09.2024 upheld the Draft Assessment Order. Pursuant to the DRP‟s directions

Highradius Technologies Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle -2(1), Hyderabad

ITA 436/HYD/2024[2020-21]Status: HeardITAT Hyderabad12 Nov 2025AY 2020-21

Bench: Us:

Section 143(1)Section 143(3)Section 144B

Income Tax Act, 1961 (“the Act”) dated 2 HighRadius Technologies Private Limited 25.02.2024, which in turn arises from the directions issued by the Dispute Resolution Panel-1, Bengaluru (for short, “DRP”) for the assessment year 2020–21. The assessee company has assailed the impugned order on the following grounds ... order passed u/s 92CA(3) of the Act, dated 27/03/2023, suggested an upward adjustment of Rs. 12,32,46,335/-. 14. Thereafter, the Dispute Resolution Panel-1, Bengaluru, vide its order dated 30.01.2024, directed the TPO to exclude certain comparables 10 HighRadius Technologies Private Limited from the software development segment

Sony India Private Limited, Delhi vs. ACIT Circle 22(2), Delhi

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

ITA 3851/DEL/2024[AY 2020-21]Status: DisposedITAT Delhi12 Nov 2025

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Roysony India Private Limited, Vs. Acit, Circle 22 (2), A – 18, Mohan Cooperative Indl. Area, New Delhi. Mathura Road, New Delhi – 110 044. (Pan :Aabcs1571Q) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 23.09.2025 Date Of Order : 12.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appealpreferred By The Assesseeis Directed Against The Assessment Order Dated 30.07.2024Passed By The Assessment Unit, Income Tax Department Under Section 143(3) Read With Section 144C(13) R.W.S. 144Bof The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020- 21Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :-

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR

Section 143(3)Section 144C(13)Section 144C(5)

144C(13) r.w.s. 144Bof the Income-tax Act, 1961 (for short ‘the Act”) for Assessment Year 2020- 21pursuant 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, the final assessment

Concur Technologies (India) Private Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle 2(2)(1), Bangalore

Appeal of the assessee is partly allowed as indicated above

ITA 2550/BANG/2024[2021-22]Status: DisposedITAT Bangalore11 Nov 2025AY 2021-22

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2021-22

For Appellant: Shri Chavali Narayan, CAFor Respondent: Dr Divya K J, CIT(DR)(ITAT), Bengaluru

Section 144Section 144BSection 144C

with section 144C (13) read with section 144B of the Income Tax Act, 1961 (the Act) pursuant to the direction issued by the Dispute Resolution Panel, Bangalore (the learned DRP) on 17 September 2024 under section 144C (5) of the Act wherein the total income of Page ... 28/12/2023 wherein the total income of the assessee was determined at 46,00,90,995/–. The assessee filed its objections before the learned dispute resolution panel. During hearing before the panel, the factual report from the transfer pricing officer was asked for and rejoinder of the assessee was also taken

Sap India Private Limited, Bangalore vs. Deputy Commissioner of Income-Tax, Circle 6(1)(1), Bangalore

In the result appeal filed by the assessee is partly allowed

ITA 704/BANG/2023[2019-20]Status: DisposedITAT Bangalore11 Nov 2025AY 2019-20

Bench: Shri Prashant Maharishi & Shri Soundararajan K, Jm

Section 115Section 143Section 144BSection 144CSection 234DSection 37Section 92C

Income Tax (Transfer Pricing) 2 (2) (1) Bangalore (the learned TPO) on 28th of January 2022 and the direction issued by The Dispute Resolution Panel 2, Bangalore (the learned dispute resolution panel/the DRP) under Section 144C (5) of the act wherein the total income of the assessee as per return ... that the order passed is barred by limitation, ground No. 3 absence of document identification No. in the direction issued by the learned dispute resolution panel, were not pressed and therefore same are dismissed. 3. The ground No. 9 regarding charging of interest under Section 234D

Haseeb Mohammed Iqbal Shaikh, Mumbai vs. ITO, Int Tax 4(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 235/MUM/2025[2016-17]Status: DisposedITAT Mumbai11 Nov 2025AY 2016-17

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2016-17 Haseeb Mohammed Iqbal Shaikh Income Tax Officer, 9/301, Vijay Park Ghodbunder (International Taxation)- Road, Kasarvadavli, Thane, Vs 4(2)(1), Mumbai - 400601 Mumbai (Pan : Bscps9388A) (Appellant) (Respondent) Present For: Assessee : Shri Nishant Thakkar, Shri Rajesh Poojary & Ms. Jasmin Amalsadwala, Advocates Revenue : Shri Krishna Kumar, Sr. Dr Date Of Hearing : 14.08.2025 Date Of Pronouncement : 11.11.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Assessment Passed Under The Directions Of Dispute Resolution Panel-1, Mumbai, Vide Order No. Itba/Drp/F/144C(5)/2024-25/1070521602(1), Dated 21.11.2024, Passed U/S. 144C(5) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), For Assessment Year 2016-17. 2. Grounds Taken By The Assessee Are Reproduced As Under: “1. Reassessment Proceedigns: 1.1 The Income Tax Officer 1 (1), Thane ("The J.A.O.") Erred In Passing The Order U/S. 148A(D) Of The Income Tax Act, 1961 (Hereinafter Referred To As "The Act") Dated 28Th March 2023 & Issuing Notice U/S. 148 Of The Act On 29Th March 2023 In Violation Of The Provisions Of Section 151A Of The Act Read With E-Assessment Of Income Escaping Assessment Scheme, 2022. 2 Haseeb Mohammed Iqbal Shaikh Ay 2016-17

For Appellant: Shri Nishant Thakkar, Shri Rajesh Poojary and Ms. Jasmin Amalsadwala, AdvocatesFor Respondent: Shri Krishna Kumar, Sr. DR

Section 144Section 144C(5)Section 147Section 148Section 148ASection 151ASection 56Section 56(2)(vii)Section 69Section 69A

GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the assessment passed under the directions of Dispute Resolution Panel-1, Mumbai, vide order no. ITBA/DRP/F/144C(5)/2024-25/1070521602(1), dated 21.11.2024, passed u/s. 144C(5) of the Income-tax Act, 1961 (hereinafter referred ... held as null and void. WITHOUT FURTHER PREJUDICE TO THE ABOVE: 2. ADDITION U/S. 69 OF THE АСТ: 2.1 The Hon'ble Dispute Resolution Panel (hereinafter referred to as "the DRP") erred in directing the A.O. to confirm the addition of Rs. 4,41,000/- to the income

Linklaters LLP, London vs. Assistant Commissioner of Income Tax (International Taxation), Circle (3)(1)(2), Mumbai

ITA 1222/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Nov 2025AY 2022-23

Bench: Shri Saktijit Dey & Shri Girish Agrawalassessment Year: 2022-23 Linklaters Llp Assistant Commissioner Of C/O. Deloitte Haskins & Sells Income Tax (International Llp, Tower 3, 27-32 Floor, One Taxation) - 3(1)(2), International Centre, Mumbai Elphinstone Mill Compound, Vs. Senapati Bapat Marg, Elphinstone (West), Mumbai – 400 013. (Pan: Aabcl5182G) (Appellant) (Respondent) Present For: Assessee : Shri Niraj Sheth, Advocate Revenue : Shri Krishna Kumar, Sr. Dr Date Of Hearing : 14.08.2025 Date Of Pronouncement : 11.11.2025

For Appellant: Shri Niraj Sheth, AdvocateFor Respondent: Shri Krishna Kumar, Sr. DR

Section 144C(5)Section 9Section 9(1)Section 9(1)(vii)

GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the assessment order passed under the directions of Dispute Resolution Panel-1, Mumbai, vide order no. ITBA/DRP/F/144C(5)/2024-25/1070782259(1), dated 30.11.2024, u/s. 144C(5) of the Income-tax Act, 1961 (hereinafter referred ... Linklaters LLP AY 2022-23 2. Grounds taken by the assessee are reproduced as under: 1. The learned Hon'ble Dispute Resolution Panel ('Panel) erred in relying on its finding for the AY 2016 17. 2. The learned AO erred in computing the total income of the appellant

Uk Grid Solutions Limited, Stafford, United Kingdom vs. Deputy Commissioner of Income Tax, Circle Int Tax 3(1)(1)Del, Delhi

In the result, appeal of the assessee is allowed in terms aforesaid

ITA 2042/DEL/2025[2022-23]Status: DisposedITAT Delhi10 Nov 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2022-23] Uk Grid Solutions Limited, The Deputy Commissioner Of Income St Leonards Building, Harry Tax, Circle International Taxation Kerr Dive, Stafford St16 1Wt, Vs -3(1)(1), Civic Centre, Minto Road United Kingdom-99999 New Delhi-110002 Pan-Aaica6271A Assessee/Appellant Revenue/Respondent

Section 143(3)Section 44BSection 9(1)(vii)

taxation of Global Operation Fees as FTS was decided by the Tribunal in assessee’s favour. Referring to para 6 of the Dispute Resolution Panel directions, the ld. Counsel pointed that the ld. Dispute Resolution Panel records that the factual and legal matrix in AY 2022-23 is similar ... Department vehemently defended the impugned order and prayed for dismissing appeal of the assessee. The ld. CIT-DR reiterated findings of the Dispute Resolution Panel and the Assessing Officer and prayed for confirming the additions. 5. Both sides heard, orders of the authorities below examined. A perusal of DRP directions

John Wiley & Sons, Inc., United States of America vs. Assistant Commissioner of Income Tax, International Taxation, Circle 2(1)(2), New Delhi, Civic Centre, Minto Road

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

ITA 2029/DEL/2025[2022-23]Status: DisposedITAT Delhi10 Nov 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2022-23]

Section 143(3)Section 144C(13)Section 153Section 270ASection 9(1)(vi)Section 9(1)(vii)

passed u/s 143(3)/144C(13) of the Income Tax Act, 1961 (hereinafter ‘the Act’) pursuant to the directions of the ld. Dispute Resolution Panel (in short ‘ ld. DRP')dated 07.12.2024 pertaining to Assessment Year 2022-23. 2. Grounds of appeal raised by the assessee are as under:- 1. That ... returned income of INR 18,308,194 making an addition of INR 181,19,094, pursuant to the directions issued by the Dispute Resolution Panel ('DRP"). 2 That on the facts and in circumstances of the case and in law, the AO / DRP have erred in holding the Revenues amounting

Tungsten Automation England Ltd, United Kingdom vs. DCIT, Intl Taxation Circle-3(1)(1), Delhi

In the result, appeal of the assessee is partly allowed

ITA 1957/DEL/2025[2018-19]Status: DisposedITAT Delhi10 Nov 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2018-19]

Section 147Section 9(1)Section 9(1)(vii)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘D’: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI BRAJESH

DCIT Circle 4(2), New Delhi vs. Canon India Pvt. Ltd., New Delhi

In the result, to sum up and conclude:

ITA 1038/DEL/2023[2005-06]Status: DisposedITAT Delhi10 Nov 2025AY 2005-06

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR

Section 10ASection 143(3)Section 254Section 92C

under: “1. That on the facts and circumstances of the case and in law, the Ld. AO as well as Hon'ble Dispute Resolution Panel ('DRP') has erred in not granting complete credit of taxes paid by it in Japan on export Page 2 of 38 ITA No. 5855/DEL/2021 ... Income Tax Act, 1961. 1.1. That on the facts and circumstances of the case and in law, the Ld. AO and Hon'ble Dispute Resolution Panel ('DRP') has erred in not allowing complete credit of taxes paid by assessee in Japan on export revenues from sale of software amounting

Ecoenergy Insights Ltd ( Formerly Known As Chubb Alba Control Systems P.Ltd), New Delhi vs. DCIT, Circle-4(2), New Delhi

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

ITA 2321/DEL/2022[2018-19]Status: DisposedITAT Delhi10 Nov 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR

Section 143(2)Section 144C(13)Section 144C(5)Section 147Section 92C

r.w.s. 144B of the Income-tax Act, 1961 (for short ‘the Act”) for AY 2018-19 pursuant to the directions of the Dispute Resolution Panel u/s 144C(5) of the Act. 2 2. Brief facts of the case are, assessee revised the return of income ... passed by the Assessment Unit, Income Tax Department hereinafter referred to as "AU or "AO"] pursuant to direction issued by the Hon'ble Dispute Resolution Panel [hereinafter referred to as DRP] under Section 143(3) read with Section 144C(03) and Section 1448 of the Income-tax Act, 1961 (hereinafter

Canon India Pvt. Ltd, Gurugram vs. Neac, Delhi

In the result, to sum up and conclude:

ITA 585/DEL/2021[2003-04]Status: DisposedITAT Delhi10 Nov 2025AY 2003-04

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR

Section 10ASection 143(3)Section 254Section 92C

Argos Holdings Pte. Ltd., Singapore vs. Deputy Commissioner of Income Tax, Circle Int Tax 1(1)(1), Delhi

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

ITA 3633/DEL/2025[2017-18]Status: DisposedITAT Delhi06 Nov 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Saroj Kumar Dubey, CIT DR

Section 144C(5)Section 147Section 148Section 148ASection 151Section 194LSection 1ISection 260Section 6(3)Section 6(3)(ii)

Income-tax Act, 1961 (for short ‘the Act”) for Assessment Years 2015-16 & 2017- 18pursuant 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 disposed ... order null and void ab initio and liable to be quashed. Ground No.2: That on the facts and circumstances of the cases the Dispute Resolution Panel - 1, New Delhi ("DR P") erred in upholding the additions without proper consideration or the material on record and without applying an independent judicial

Argos Holdings Pte. Ltd., Singapore vs. Deputy Commissioner of Income Tax, Circle Int Tax 1(1)(1), Delhi

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

ITA 3632/DEL/2025[2015-16]Status: DisposedITAT Delhi06 Nov 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Saroj Kumar Dubey, CIT DR

Section 144C(5)Section 147Section 148Section 148ASection 151Section 194LSection 1ISection 260Section 6(3)Section 6(3)(ii)

Oxbow Energy Solutions B.V., Thane vs. The Deputy Commissioner of Income, Mumbai

The appeal of the assessee is partly allowed

ITA 4769/MUM/2023[2021-2022]Status: DisposedITAT Mumbai04 Nov 2025AY 2021-2022

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nishant Thakkar, Ms. JasminFor Respondent: Shri. Krishna Kumar, Sr. DR

Section 143(3)

dated 25.10.2023 for AY 2021-22. The assessee raised the following grounds: “1. The Assessing Officer (AO) as well as the Dispute Resolution Panel (DRP) erred in assessing Rs. 37,63,060/- as income liable to tax in India. 2 Oxbow Energy solutions B.V. 2. The AO/DRP erred in holding

Mrs Shireen J. Dastur, Mumbai vs. ITO Int Taxation Ward 2(1)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 2204/MUM/2022[2018-19]Status: DisposedITAT Mumbai04 Nov 2025AY 2018-19

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2018-19 Shireen J. Dastur Income Tax Officer, 330, Coral Avenue, (International Taxation), New Port Beach, Ward 2(1)(1), California Vs. Mumbai 92662 Usa (Pan : Ctlpd0257N) (Appellant) (Respondent) Present For: Assessee : Shri P.J. Pardiwala, Sr. Advocate & Ms. Gunjan Kakkad, Advocate Revenue : Shri Krishna Kumar, Sr. Dr Date Of Hearing : 11.08.2025 Date Of Pronouncement : 04.11.2025 O R D E R

For Appellant: Shri P.J. Pardiwala, Sr. Advocate and Ms. Gunjan Kakkad, AdvocateFor Respondent: Shri Krishna Kumar, Sr. DR

Section 144C(5)Section 234B

GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the assessment order passed under the directions Dispute Resolution Panel-2, Mumbai, vide order no. ITBA/DRP/F/144C(5)/2022-23/1043696726(1), dated 30.06.2022, u/s. 144C(5) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), for Assessment ... note that in the 3 Shireen J Dastur AY 2018-19 impugned assessment order passed pursuant to directions given by the ld. Dispute Resolution Panel (DRP), it has been categorically held that money received by the assessee is taxable under the head ‘Capital Gains’. 4. Facts in brief as culled

Cppgroup Services Limited, Leeds, United Kingdom vs. Assistant Commissioner of Income-Tax, Delhi

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

ITA 980/DEL/2025[2022-23]Status: DisposedITAT Delhi04 Nov 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2022-23]

Section 143(3)Section 234B

Officer dated 23.12.2024 passed u/s 143(3)/144C(13) of the Income Tax Act, 1961 (hereinafter ‘the Act’) arising out of directions of Dispute Resolution Panel (hereinafter referred to as ‘DRP') dated 26.11.2024 pertaining to Assessment Year 2022-23. 2. The grounds of appeal are as under ... assessee for the present assessment year cannot be held as taxable as FTS by the Assessing Officer and confirmed by the Dispute Resolution Panel. 4. We have heard both the parties and perused the material available on record. The above cited order dated 22.12.2022 of the Tribunal has been perused

Wts Energy Dmcc, Dubai vs. Assistant Commissioner of Income Tax, Delhi

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

ITA 1891/DEL/2025[AY 2022-23]Status: DisposedITAT Delhi04 Nov 2025

Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI BRAJESH KUMAR SINGH (Accountant Member)

For Appellant: S/Shri Sachit Jolly, Sr. Advocate along with Sohum Dua, Abhyudaya Shankar BajpaiFor Respondent: Shri M.S Nethrapal, CIT-DR

Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 234ASection 270A

material furnished on record. 4. On the facts and circumstances of the case and in law, both the Ld. AO and Hon’ble Dispute Resolution Panel – 2 (‘Hon’ble DRP’) erred in holding that the Appellant did not file reply to show cause notice issued by the Ld.AO without appreciating ... Income from Other Sources’ and made addition of the entire receipts i.e. Rs.62,56,46,817/-. Thereafter, the assessee filed objection before the Dispute Resolution Panel (DRP) highlighting that the draft Assessment Order was passed without providing adequate opportunity to the assessee. Nevertheless, on merits as well the assessee made