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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

Gsma Ltd, Usa vs. ACIT Circle Intl Taxation 1(3)(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 2446/DEL/2024[2017-18]Status: DisposedITAT Delhi04 Nov 2025AY 2017-18

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.2446/िद"ी/2024(िन.व. 2017-18) Gsma Ltd., 1000 Abernathy Road, Suite 450, Atalanta, Untied State Of America ...... अपीलाथ"/Appellant Pan: Aaecg-1610-K बनाम Vs. Assistant Commissioner Of Income-Tax, International Taxation 1(3)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant By: Shri P.P Singh, Advocate "ितवादी"ारा/Respondent By: Shri M.S Nethrapal, Cit-Dr सुनवाई क" ितिथ/ Date Of Hearing : 06/08/2025 घोषणा क" ितिथ/ Date Of Pronouncement : 04/11/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 06.04.2021 Passed U/S. 143(3) R.W.S 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’), For Assessment Year 2017-18. 2. The Registry Has Issued Defect Memo Stating That The Appeal Is Time Barred By 1076 Days. The Assessee Has Filed An Application Supported By An Affidavit Citing Reasons For Delay In Filing Of Appeal.

For Appellant: Shri P.P Singh, AdvocateFor Respondent: Shri M.S Nethrapal, CIT-DR
Section 143(3)Section 9(1)(vii)

assessee @70% of the service fee received by MSAI from the third party i.e. Mobile Equipment Manufactures. The Assessing Officer (AO) and the Dispute Resolution Panel (DRP) held that the Administration Fee received by the assessee is in the nature of royalty as per Section

Valji Harji Hirani, Bhuj vs. ITO.(Int.Txn), Gandhidham

In the result, the appeal of the assessee is allowed

ITA 119/RJT/2024[2018-19]Status: DisposedITAT Rajkot03 Nov 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.119/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2018-19) Valji Harji Hirani Vs. Ito, (Int. Txn) Meghpar, Nr. Dena Bank, Gandhidham (Gujarat) – 370201 Bhuj (Gujarat) - 370430 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agjph6338K (Appellant) (Respondent) Appellant By : Shri Samir Bhuptani, Ld. Ar Respondent By : Smt. Pallavi, Ld. Cit(Dr) : 05/08/2025 Date Of Hearing Date Of Pronouncement : 03/11/2025 आदेश / O R D E R Per, Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay)-2018-19, Is Directed Against The Order Passed By The Dispute Resolution Panel(Drp-2), Vide Order Dated 29.12.2023, Which In Turn Assessment Order Passed By Income Tax Department / Assessing Officer Under Section 144C(5) Of The Income Tax Act, 1961 (In Short “The Act”), Vide Order Dated 18.01.2024. (Ita 2. Grounds Of Appeal Raised By The Assessee, Are As Follows: 1. The Learned Drp Panel Has Erroneously Applied Section 69 By Focusing On The Conditions Outlined In Section 69 Without Duly Considering The Applicant'S Submission Regarding The Source Of The Investment. It Is Emphasized That The Nre Fdrs In Question Are From Previous Years & Have Been Made From After Tax Income Earned Abroad, As Clearly Stated In The Submission. The Panel Has Failed To Acknowledge The Satisfactory Explanation Provided By The Assessee Regarding The Source Of Acquisition Of The Investment. Shri Leuva Patel Kelavani Mandal

For Appellant: Shri Samir Bhuptani, Ld. ARFor Respondent: Smt. Pallavi, Ld. CIT(DR)
Section 115BSection 144CSection 144C(5)Section 148Section 69

Sinha, JM: Captioned appeal filed by the assessee, pertaining to Assessment Year (AY)-2018-19, is directed against the order passed by the Dispute Resolution Panel(DRP-2), vide order dated 29.12.2023, which in turn assessment order passed by Income Tax Department / Assessing Officer under section 144C ... Aggrieved with the proposed addition, the applicant assessee has filed objections against the proposed assessment on 28.04.2023 before the Dispute Resolution Panel-2 (the DRP, the "Panel"), Mumbai. Hon'ble DRP, Mumbai vide DIN & Order No: ITBA/DRP/F/144C(5)/2023- 24/1059208322(1) dated 29/12/2023 has rejected the objections filed

Skechers Sarl, Mumbai vs. The Assistant Commissioner of Income Tax 4(2)(1), Mumbai

In the result the appeal filed by the assessee stands partly

ITA 2028/MUM/2025[2022-23]Status: DisposedITAT Mumbai03 Nov 2025AY 2022-23

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 143(3)Section 144CSection 144C(13)Section 153Section 234BSection 270A

without prejudice to one another On the facts and circumstances of the case and in law, the Ld. AO and the Hon'ble Dispute Resolution Panel-2, Mumbai ('DRP'): General Ground: 1. erred in assessing the total income at INR 52,06,95,454 instead of income offered ... powers of DRP are provided in section 144C of the Act which is reproduced as under for ready reference: '(5) The Dispute Resolution Panel shall, in a case where any objection is received under sub-section (2), Issue such directions, as it thinks fit, for the guidance of the Assessing

Kapa Sindhu Mitra, Usa vs. Income Tax Officer (Int Taxn)-1, Hyderabad

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 513/HYD/2024[2016-17]Status: DisposedITAT Hyderabad31 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita No.513/Hyd./2024 िनधा"रण वष"/Assessment Years 2016-2017 Kapa Sindhu Mitra, 20148, Holly Hock Terrace, The Income Tax Officer – Ash Burn, V A, Vs. [Int. Taxn)-1, Hyderabad – 500 004. United States Of America. Pan Azcpk8030D (Appellant) (Respondent) िनधा"रती "ारा/Assessee By : Sri Sashank Dundu, Advocate राज" व "ारा/Revenue By : Dr. Narendra Kumar Naik, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 29.10.2025 घोषणा की तारीख/Pronouncement: 31.10.2025 आदेश/Order Per Vijay Pal Rao:

For Appellant: Sri Sashank Dundu, AdvocateFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 144C(5)Section 147Section 148Section 148ASection 149Section 151A

dated 13.03.2024 passed u/sec.147 r.w.s.144C(13) of the Income Tax Act, 1961 [in short "the Act"] in pursuance to the Directions of the Disputes Resolution Panel-1 [in short “DRP”], Bengaluru, dated 2 ITA.No.513/Hyd./2024 23.02.2024 passed u/sec.144C(5) of the Income Tax Act, 1961, for the assessment year ... filed by the petitioner and without proper verification of information available with the department, thereby violating the principles of natural justice. 7. The Dispute Resolution Panel(DRP-1) erred in not considering the objections raised only on the ground that the said objections were not raised in the prescribed form

Dgs Technical Services Private Limited, Hyderabad vs. DCIT., Circle-8(1), Hyderabad

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

ITA 1095/HYD/2024[2021-22]Status: DisposedITAT Hyderabad31 Oct 2025AY 2021-22

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

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

r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act 1961, (in short “the Act”) in pursuant to the directions of the Dispute Resolution Panel 2 DGS Technical Services Private Limited (in short “DRP”), dated 28.08.2024 passed u/s 144C ... draft assessment order passed by the A.O. under Section 144C(1) of the Act, dated 28.11.2023, the assessee has filed objections before the Dispute Resolution Panel (DRP) -1, Bengaluru, and raised various objections, including re- 8 DGS Technical Services Private Limited characterization of services rendered by the assessee

M/S Enea Software Inc., India vs. Deputy Commissioner of Income-Tax, Circle Int. Tax 2(2)(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 986/DEL/2025[2022-23]Status: DisposedITAT Delhi31 Oct 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2022-23] M/S Enea Software Inc. Deputy Commissioner Of (Formerly Known As Openwave Income Tax, Circle Int. Tax Inc.), 1St Floor, Vs 2(2)(2), Civic Centre, Mobility Quattro Iconic Plot No. 273, Minto Road, Udyog Vihar, Phase 2, New Delhi. Gurugram, Haryana-122015 Pan- Aabco7261M Assessee Revenue

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

read with Section 144C (13) of the Income-tax Act, 1961 (“the Act”), pursuant to the directions of the Hon'ble Dispute Resolution Panel (DRP) order dated 27.12.2024 for the Assessment Year 2022-23. 1.1 Ground no.1 of the appeal is general in nature and hence needs no separate adjudication ... assessee is in appeal before us by raising the following grounds of appeal: “2. That both the Ld. AO and Hon'ble Dispute Resolution Panel-2 (DRP) have erred in law, in mis-interpreting the software licensing fee as a payment made in consideration for a 'process, entirely disregarding

Invesco Holding Company (Us) Inc., Usa vs. Assistant Commissioner of Income Tax, Circle International Taxation 2(1)(1), Delhi

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

ITA 846/DEL/2025[2022-23]Status: DisposedITAT Delhi31 Oct 2025AY 2022-23

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.846/िद"ी/2025(िन.व. 2022-23) Inveso Holding Company (Us) Inc., C/O Invesco (India) P. Ltd., 15Th Floor, Block 6, North Tower, Divyasree Orion Sez, Raidurgam, Serilingampally, Hyderabad, Telangana 5000032 ...... अपीलाथ"/Appellant Pan: Aaeci-9027-N बनाम Vs. Assisnat Commissioner Of Income-Tax, International Taxation 2(1)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant By: S/Shri Ankul Goyal & Advitya Grover, Advocates "ितवादी"ारा/Respondent By: Shri M.S Nethrapal, Cit-Dr सुनवाई क" ितिथ/ Date Of Hearing : 04/08/2025 घोषणा क" ितिथ/ Date Of Pronouncement : 31/10/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against Assessment Order Dated 20.12.2024 Passed U/S. 143(3) R.W.S 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’), For Assessment Year 2022-23. 2. Shri Ankul Goyal, Appearing On Behalf Of The Assessee Submits That The Solitary Issue In Present Appeal Is Against The Addition Of Rs.54,85,23,539/- In Respect Of Reimbursement Of Cost For Providing It/Support Services Treated As Fee

For Appellant: S/Shri Ankul Goyal & Advitya GroverFor Respondent: Shri M.S Nethrapal, CIT-DR
Section 143(3)

rendered in AY 2020-21 deleted the additions vide order dated 02.04.2025. The factual matrix in the impugned assessment year is identical. The Dispute Resolution Panel (DRP) in para 4.4.2 of the directions has recorded the fact that the issues in the impugned assessment year are similar to the issues

The Milestone Aviation Asset Holding Group No.25 Ltd., Ireland vs. ACIT Int. Tax. Circle 3(1)(1) New Delhi, New Delhi

In the result, this issue is decided in favour of the appellant assessees and against the Revenue

ITA 1351/DEL/2025[2022-2023]Status: DisposedITAT Delhi31 Oct 2025AY 2022-2023

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita No.1350/Del./2025, A.Y. 2022-23 Vertical Aviation No. 1 Ltd., Assistant Commissioner Of Dolmen House, 3Rd Floor, Income Tax, 4 Earlsfort Terrace, Vs. Circle Int. Tax. - 3(1)(1), Dublin 2, Ireland Do2E024 Civic Centre, Minto Road, Pan: Aafcv8726N New Delhi-110002 (Appellant) (Respondent) Ita No.1351/Del./2025, A.Y. 2022-23 The Milestone Aviation Assistant Commissioner Of Asset Holding Group No. 25 Income Tax, Ltd., Vs. Circle Int. Tax. - 3(1)(1), Dolmen House, 3Rd Floor, Civic Centre, Minto Road, 4 Earlsfort Terrace, New Delhi-10002 Dublin 2, Ireland D02E024 Pan: Aahct8009N (Appellant) (Respondent) Both Appellant By Sh. Sachit Jolly, Sr. Advocate Ms. Rashi Khanna, Advocate Ms. Viyushti Rawat, Advocate (Vc) Sh. Devansh Jain, Advocate Ms. Disha Jham, Advocate Sh. Soham Dua, Advocate, Sh. Hardeep Singh, Advocate & Sh. A. S. Bajpai, Advocate Both Respondent By Shri Indruj S. Rai, Spl. Counsel, Sh. Sanjeev Menon, Jr. Sc, Sh. Rahul Singh, Jr. Sc, Sh. Gaurav Kumar, Adv. Ms. Rini Handa, Jcit (Intl. Tax) Date Of Hearing 12/09/2025 Date Of Pronouncement 31/10/2025 Common & Identical.

Section 143(3)Section 153Section 194LSection 9(1)(vii)

Senior Counsel submitted that this clearly showed non-application of mind at the part of the Ld. AO and the Ld. Dispute Resolution Panel (‘DRP’) as both Authorities had mentioned incorrect facts in their orders. The Ld. Senior Counsel argued that the Ld. Special Counsel could not improve the cases

Vertical Aviation No. 1 Limited, Ireland vs. ACIT Int. Tax. Circle 3(1)(1) New Delhi, New Delhi

In the result, this issue is decided in favour of the appellant assessees and against the Revenue

ITA 1350/DEL/2025[2022-2023]Status: DisposedITAT Delhi31 Oct 2025AY 2022-2023

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita No.1350/Del./2025, A.Y. 2022-23 Vertical Aviation No. 1 Ltd., Assistant Commissioner Of Dolmen House, 3Rd Floor, Income Tax, 4 Earlsfort Terrace, Vs. Circle Int. Tax. - 3(1)(1), Dublin 2, Ireland Do2E024 Civic Centre, Minto Road, Pan: Aafcv8726N New Delhi-110002 (Appellant) (Respondent) Ita No.1351/Del./2025, A.Y. 2022-23 The Milestone Aviation Assistant Commissioner Of Asset Holding Group No. 25 Income Tax, Ltd., Vs. Circle Int. Tax. - 3(1)(1), Dolmen House, 3Rd Floor, Civic Centre, Minto Road, 4 Earlsfort Terrace, New Delhi-10002 Dublin 2, Ireland D02E024 Pan: Aahct8009N (Appellant) (Respondent) Both Appellant By Sh. Sachit Jolly, Sr. Advocate Ms. Rashi Khanna, Advocate Ms. Viyushti Rawat, Advocate (Vc) Sh. Devansh Jain, Advocate Ms. Disha Jham, Advocate Sh. Soham Dua, Advocate, Sh. Hardeep Singh, Advocate & Sh. A. S. Bajpai, Advocate Both Respondent By Shri Indruj S. Rai, Spl. Counsel, Sh. Sanjeev Menon, Jr. Sc, Sh. Rahul Singh, Jr. Sc, Sh. Gaurav Kumar, Adv. Ms. Rini Handa, Jcit (Intl. Tax) Date Of Hearing 12/09/2025 Date Of Pronouncement 31/10/2025 Common & Identical.

Section 143(3)Section 153Section 194LSection 9(1)(vii)

Senior Counsel submitted that this clearly showed non-application of mind at the part of the Ld. AO and the Ld. Dispute Resolution Panel (‘DRP’) as both Authorities had mentioned incorrect facts in their orders. The Ld. Senior Counsel argued that the Ld. Special Counsel could not improve the cases

Miteshkumar Dayaljibhai Pabari, Bhatiya vs. Assistant Commissioner/ Deputy Commissioner, Rajkot

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

ITA 420/RJT/2025[2020-21]Status: DisposedITAT Rajkot30 Oct 2025AY 2020-21

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 420 /Rjt/2025 (िनधा"रण वष"/Assessment Year: (2020-21) Miteshkumar Dayaljibhai Pabari Assistant Commissioner/Deputy Commissioner, International C/O Dayaljibhai Pabari, Shreeji Catlery Vs. Taxation Rajkot, Stores, Main Bajar, Bhatiya, Devbhoomi Dwarka, Room No. 312, Income Tax Office, Amruta Estate Building, Near Girnar Dwarka-361315(Gujarat) Cinema, M.G. Road, Rajkot – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bctpp7290M (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mahesh Paun, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 151Section 274Section 69

above variations made to its total income as per the return of income filed or to file its objections, if any, before the Dispute Resolution Panel, as per the provisions Page 5 of 12 ITA 420/RJT/2025 MITESHKUMAR PABARI of Section 144C(2) of the Act at the following address ... Secretary, Dispute Resolution Panel-2, World Trade Center, Cufffe Parade, Colaba, Mumbai- 400005, failing which the final assessment order u/s 147 r.w.s.144C(3)/144C(13) of the Income-tax Act shall be passed assessing the total income of the assessee as proposed here-in-above. 8.Aggrived by the above draft

Bundy India Limited, Vadodara vs. The Dy. CIT., Circle-1(1), Baroda

In the result, Ground Number 6 of the assessee’s appeal is allowed for statistical purposes

ITA 1403/AHD/2016[2009-10]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2009-10

Bench: Annapurna Gupta & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1403/Ahd/2016 िनधा"रण वष" /Assessment Year : 2009-10 Bundy India Limited The Dy.Cit बनाम/ Plot No.2, Circle-1(1) V/S. Gidc Industrial Estate, Baroda Makarpura Vadodaria - 390 010 "थायी लेखा सं./Pan: Aaacb 3039 M (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri S.N. Soparkar, Sr. Advocate Revenue By : Shree Veerbadram Vislavath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 31/07/2025 घोषणा की तारीख /Date Of Pronouncement: 30/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm:

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shree Veerbadram Vislavath, Sr.DR
Section 133(6)Section 250Section 92CSection 92C(1)Section 92C(3)

Rule 10B(2), (3) and (4) of the Rules. 7. The Id. CIT(A) has erred on facts in disregarding directions given by Dispute Resolution Panel (DRP) in appellant's own case of AY 2010-11 with respect to allowance of management fees in full as well as removal ... exclusion of comparables, alleging violation of the principles of natural justice and arbitrariness in selection. However, the CIT(A) observed that the Dispute Resolution Panel (DRP) in the assessee’s own case for AY 2010–11 had already upheld similar rejections and inclusions of comparables. Following the DRP’s reasoning

Ncr Global Solutions Limited, Ireland vs. Deputy Commissioner of Income-Tax, Circle-2(2)(2), International Tax, New Delhi

In the result, both the appeals of the assessee are allowed as indicated above

ITA 1885/DEL/2025[2022-23]Status: DisposedITAT Delhi30 Oct 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 142(1)Section 143(2)Section 143(3)

Income-tax Act, 1961 (“the Act”), ITA No.-1885/Del/2025 NCR Global Solu"ons Ltd. pursuant to the directions of the Hon'ble Dispute Resolution Panel (DRP) order dated 10.12.2024 for the Assessment Year 2022-23. 1.1 At the outset, the Ld. AR submitted that the issue in the present ... under section 144C of the Income Tax Act (i) TPO/AO are directed to complete the assassmont as per the above directions of the Dispute Resolution Panel (ii) In view of Section 144C(13) quoted below, TPO/AO are directed not to make any further Inquiries with the assessee- “ (13)Upon receipt

Aka Ausfuhrkredit-Gesellschaft Mbh, Outside India vs. Deputy Commissioner of Income-Tax Int Tax Circle 1(1)(1), Delhi

In the result, appeal of the assessee is partly allowed

ITA 1766/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Oct 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 115A(1)(b)Section 147Section 148Section 9Section 9(1)(vi)

with Sections 144C(13) of the Income-tax Act, 1961 (“the Act”), ITA No.- 1766/Del/2025 pursuant to the directions of the Hon'ble Dispute Resolution Panel (DRP) order dated 29.12.2024 for the Assessment Year 2018-19. 2. Ground nos. 1, 2 and 3 are not pressed and therefore, dismissed

Snc Lavalin Inc., Delhi vs. The Assistant Commissioner of Income Tax/ Circle International Tax 3(1)(2), Delhi

In the result, the Appeal of the assessee is allowed, the Stay Application of the assessee is dismissed as infructuous

ITA 1760/DEL/2025[2022-23]Status: DisposedITAT Delhi30 Oct 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 143(3)Section 144C(1)

Income-tax Act, 1961 (“the Act”), ITA No.- 1760/Del/2025 SNC Lavalin Inc. pursuant to the directions of the Hon'ble Dispute Resolution Panel (DRP) order dated 31.12.2024 for the Assessment Year 2022-23. 2. At the outset, the Ld. AR submitted that the present case is squarely covered ... following grounds of appeal: “1. On the facts and in the circumstances of the case and in law, the Hon'ble Dispute Resolution Panel ('Hon'ble DRP') and the Learned Assistant Commissioner of Income Tax, Circle International Tax 3(1)(2), New Delhi ('Ld. AO') (collectively referred as "the Revenue

Enel Green Power India Private Limited, Mayur Vihar, East Delhi vs. DCIT Circle 7(1), Delhi, Cr Building, ITO

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

ITA 4298/DEL/2024[2020-2021]Status: DisposedITAT Delhi30 Oct 2025AY 2020-2021

Bench: Shri S.Rifaur Rahman & Shri Sudhir Pareekenel Green Power India Private Limited, Vs. Dcit, Circle 7(1), S – 2, Manish Chambers, Delhi. Dda Local Shopping Complex, Mayur Vihar, Phase Ii, Delhi – 110 091. (Pan : Aaecb2266J) (Appellant) (Respondent) Assessee By : Shri Yishu Goel, Ar Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 13.10.2025 Date Of Order : 30.10.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2024 Passed By The Income Tax Department, Assessment Unit U/S 143(3) Read With Section 144C(13)/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.

For Appellant: Shri Yishu Goel, ARFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)

/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. 2 2. The Ld. AR for the assessee has submitted that since the assessee has settled the issue under

Knr Constructions Limited, Hyderabad vs. ACIT, Central Circle-2(2), Hyderabad

In the result, appeal filed by the assessee is dismissed

ITA 500/HYD/2022[2018-19]Status: DisposedITAT Hyderabad29 Oct 2025AY 2018-19
For Appellant: Shri A.V.Raghuram, AdvocateFor Respondent: : Smt. U Mini Chandran, CIT(DR)
Section 143(2)Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 80Section 92C

assessee has raised the following grounds of appeal: 1. The learned AO, TPO and the Dispute Resolution Panel have erred in law and in the facts and circumstances of the case in adopting the average of two irrigation projects as comparable for determining the ALP of Yedula Irrigation project carried ... order under section 144C of the Act on 08.09.2021. Against the draft order of Ld. AO, the assessee filed objections before the Learned Dispute Resolution Panel ("Ld. DRP"). The Ld. DRP, vide directions under section 144C(5) of the Act dated 29.06.2022, issued certain modifications. The Ld. DRP also passed

Celestial Sverige Aircraft Leasing Worldwide Ab, Stockholm, Sweden vs. Assistant Commissioner of Income -Tax, Circle 1(2)(1), International Tax, Delhi, Civic Centre, Minto Road, New Delhi

In the result, this issue is decided in favour of the assessee/appellant and against the Department

ITA 1479/DEL/2025[2022-23]Status: DisposedITAT Delhi29 Oct 2025AY 2022-23

Counsel submits that though the assessee has raised other issues viz. tenability of the impugned final assessment order and directions of the Dispute Resolution Panel (DRP) beyond jurisdiction in ground no. 2 and 4 of appeal, respectively, the assessee is not pressing said grounds. 3. Per contra, M.S Nethrapal representing

Celestial Aviation Trading 69 Limited, Shannon, Ireland vs. Assistant Commissioner of Income-Tax, Circle 1(2)(1), International Tax, Delhi, Civic Centre, Minto Road, New Delhi

In the result, this issue is decided in favour of the assessee/appellant and against the Department

ITA 1465/DEL/2025[2022-23]Status: DisposedITAT Delhi29 Oct 2025AY 2022-23

Counsel submits that though the assessee has raised other issues viz. tenability of the impugned final assessment order and directions of the Dispute Resolution Panel (DRP) beyond jurisdiction in ground no. 2 and 4 of appeal, respectively, the assessee is not pressing said grounds. 3. Per contra, M.S Nethrapal representing

Celestial Aviation Trading 68 Limited, Shannon, Ireland vs. Assistant Commissioner of Income-Tax, Circle 1(2)(1), International Tax, Delhi, Civic Centre, Minto Road, New Delhi

In the result, this issue is decided in favour of the assessee/appellant and against the Department

ITA 1421/DEL/2025[2022-23]Status: DisposedITAT Delhi29 Oct 2025AY 2022-23

Counsel submits that though the assessee has raised other issues viz. tenability of the impugned final assessment order and directions of the Dispute Resolution Panel (DRP) beyond jurisdiction in ground no. 2 and 4 of appeal, respectively, the assessee is not pressing said grounds. 3. Per contra, M.S Nethrapal representing

Celestial Aviation Trading 14 Limited, Shannon, Ireland vs. Assistant Commissioner of Income-Tax, Circle 1(2)(1), International Tax, Delhi, Civic Centre, Minto Road, New Delhi

In the result, this issue is decided in favour of the assessee/appellant and against the Department

ITA 1420/DEL/2025[2022-23]Status: DisposedITAT Delhi29 Oct 2025AY 2022-23

Counsel submits that though the assessee has raised other issues viz. tenability of the impugned final assessment order and directions of the Dispute Resolution Panel (DRP) beyond jurisdiction in ground no. 2 and 4 of appeal, respectively, the assessee is not pressing said grounds. 3. Per contra, M.S Nethrapal representing