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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

Michael Page International Recruitment Pvt Ltd, Mumbai vs. DCIT Circle 14(1)(1), Mumbai

ITA 6748/MUM/2024[2021-22]Status: DisposedITAT Mumbai16 Oct 2025AY 2021-22
Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 37Section 41Section 92D

Income Tax Act, 1961 [hereinafter referred to as 'the Act'], as per directions, dated 25/09/2024, issued by the Commissioner of Income Tax (Dispute Resolution Panel-3), Mumbai 3 (hereinafter referred to as 'the DRP') under Section 144C(5) of the Act for the Assessment Year 2021-2022. 2. The Assessee ... Unit, Income Tax Department ('Ld. AO') and directions issued under section 144C(5) of the Act dated 25 September 2024 by the Ld. Dispute Resolution Panel ('Ld. DRP') is erroneous, bad in law and is liable to be quashed. Ground No.2: Time Limit for completion of assessment under section

Synacor Inc., Hamburg vs. ACIT, Int.Tax. Circle- 3(1)(2), Delhi

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

ITA 1802/DEL/2025[2018-19]Status: DisposedITAT Delhi16 Oct 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.1802/िद"ी/2025(िन.व. 2018-19) Synacor Inc. 485, Sunset Drive, Office #114, Hamburg, Ny 14075 ...... अपीलाथ"/Appellant Pan: Aaxcs-8643-K बनाम Vs. Assistant Commissioner Of Income Tax, International Taxation, Circle 3(1)(2), ..... "ितवादी/Respondent Civic Centre, Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant By : Shri Deepak Chopra, Ms. Priya Tandon & Ms. Seetal Kandpal, Advocates "ितवादी"ारा/Respondent By : Shri M.S Nethrapal, Cit(Dr) सुनवाई क" ितिथ/ Date Of Hearing : 16/10/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 16/10/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 15.01.2025, Passed U/S. 147 R.W.S 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’), For Assessment Year 2018-19. 2. Shri Deepak Chopra, Appearing On Behalf Of The Assessee At The Outset Submitted That Though The Assessee Has Raised Multiple Grounds Of Appeal, However, The Effective Grounds Assailing The Addition By Treating Sale Of Software Licenses As Fee For Technical Services (Fts) Are Ground No. 8, 10 & 16 Of Appeal.

For Appellant: Shri Deepak Chopra, Ms. Priya Tandon &For Respondent: Shri M.S Nethrapal, CIT(DR)
Section 147

restricted his arguments only to ground no. 8, 10 and 16 of appeal. The same are reproduced herein below: “8. That the Respondent/ Dispute Resolution Panel ("DRP") erred on facts and in law in not appreciating that receipts in the hands of the Appellant for provision of software licences

Altera Digital Health (India) LLP (Formerly Known As Allscripts (India) LLP), Vadodara vs. The Dy.CIT, Circle-1(1)(1), Vadodara

In the result, Ground Number 11 of the assessee’s appeal is allowed for statistical purposes

ITA 359/AHD/2022[2018-19]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2018-19

Bench: Smt. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

Section 92C(1)

SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER:- This appeal has been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax, Dispute Resolution Panel-2, (in short “Ld. CIT(DRP-2)”), Mumbai-2 vide order dated 24.04.2022 passed for A.Y. 2018-19. I.T.A No. 359/Ahd/2022 ... without prejudice to the others General Ground 1 On the facts and in the circumstances of the case and in law, the Learned Dispute Resolution Panel (Ld. DRP) erred in confirming the addition proposed by the Learned Assessing Officer (Ld. AG) Learned Transfer Pricing Officer

Abhishek Reddy Boyapally, Hyderabad vs. ITO (Int Taxn) - 2, Hyderabad

In the result, the appeal of the assessee is allowed

ITA 352/HYD/2025[2015-16]Status: DisposedITAT Hyderabad15 Oct 2025AY 2015-16

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.352/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2015-16) Shri Abhishek Reddy Vs. Income Tax Officer Boyapally, Hyderabad International Taxation-2, Pan: Bodpb0397F Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Ca Y. V. Bhanu Narayan Rao रधजस् व द्वधरध/Revenue By: Dr.Narendra Kumar Naik, Cit(Dr) सुिवधई की तधरीख/Date Of Hearing: 15/10/2025 घोर्णध की तधरीख/Pronouncement: 17/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Abhishek Reddy Boyapally (“The Assessee”), Feeling Aggrieved By The Assessment Order Passed By The Ito, International Taxation-2, Hyderabad (“Ld. Ao”), Dated 25.12.2024 For The A.Y 2015-16. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: CA Y. V. Bhanu Narayan RaoFor Respondent: Dr.Narendra Kumar Naik, CIT(DR)
Section 139Section 144BSection 144CSection 147Section 148Section 148A

Term Capital Gain on the sale of immovable property. Against the said draft order the assessee filed objections on 02.04.2024 before the Learned Dispute Resolution Panel (“Ld. DRP”). Finally, after the directions of Ld. DRP dated 04.12.2024, the Ld. AO passed the final assessment order under section 147 read with

Ramagopal Varma Ramaraju, Hyderabad vs. ITO, Interenational Taxation-2, Hyderabad

In the result, the appeal filed by the assessee arising from the assessment order passed u/sec

ITA 1302/HYD/2025[2015-16]Status: DisposedITAT Hyderabad15 Oct 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /It(It)A No.507/Hyd/2025 & Ita.No.1302/Hyd./2025 िनधा"रण वष"/Assessment Year 2015-2016 Ramgopal Varma The Income Tax Officer Ramaraju, Hyderabad. Vs. [Int.Taxn]-2, Hyderabad Pin – 500 060. Telangana. Pin - 500 004. Telangana. Pan Arppr7316E (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri S Rama Rao, Advocate Dr. Narendra Kumar Naik, Cit-Dr राज" व "ारा/Revenue By: & Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 15.10.2025 घोषणा की तारीख/Pronouncement: 15.10.2025 आदेश/Order Per Vijay Pal Rao:

For Appellant: Sri S Rama Rao, AdvocateFor Respondent: And Dr. Sachin Kumar, Sr. AR
Section 139(1)Section 144C(1)Section 144C(5)Section 147Section 148Section 69ASection 69C

A.No.507/Hyd/2025 and ITA.No.1302/Hyd./2025 by the assessee viz., “Ramgopal Varma Ramaraju” are directed against the Directions dated 25.11.2024 of the Disputes Resolution Panel-1, Bengaluru 2 ITA.Nos.507 & 1302/Hyd./2025 and the Order dated 24.06.2025 of the Commissioner of Income Tax (Appeals)-10, Hyderabad, respectively, for the assessment ... passed Draft Assessment Order u/sec.144C(1) of the Act on 14.02.2024. Against the Draft Assessment Order, the assessee has filed objections before the Disputes Resolution Panel [in short “DRP”] on 14.03.2024 which were disposed of by the DRP vide Directions dated 25.11.2024 passed u/sec.144C(5) of the Act by holding

Manimozhian Vaideki, Sivagangai vs. ACIT, International Taxation Circle, Madurai

In the result, the appeal of the assessee is allowed

ITA 2025/CHNY/2025[2016-17]Status: DisposedITAT Chennai15 Oct 2025AY 2016-17

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2025/Chny/2025 यनिाारणवर्ा / Assessment Year:2016-17 Manimozhian Vaideki, The Assistant Commissioner No.77, Ward-1, Devappattu Vs. Of Income Tax, Kallal, International Taxation Circle, Sivagangai, Madurai. Tamil Nadu-630 305. [Pan:Azcpv7593C] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr.N.Arjun Raj, Advocate प्रत्यर्थीकीओरसे/Revenue By : Ms.R.Anitha, Addl.Cit

For Appellant: Mr.N.Arjun Raj, AdvocateFor Respondent: Ms.R.Anitha, Addl.CIT
Section 144C(5)Section 148Section 148ASection 149Section 149(1)(a)

submitted that Assessee is a non-resident Assessee and after the draft assessment order was passed, the Assessee went before the Learned Dispute Resolution Panel by filing its objections. The Learned Dispute Resolution Panel issued directions under section 144C(5) of the Act and before the finalization of the final

Assimilate Solutions India Pvt. Ltd., Delhi vs. DCIT Circle, 1(1), Delhi

In the result, the ground raised by the assessee in this regard is dismissed

ITA 5357/DEL/2024[2021-22]Status: DisposedITAT Delhi15 Oct 2025AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Vimal Kumarassimilate Solutions India Private Limited, Vs. Dcit/Acit, C/O Sanjiv Sapra & Associates Llp, Circle 1 (1), Chartered Accountants, New Delhi. C – 763, New Friends Colony, New Delhi – 110 025. (Pan :Aakca4501H) (Appellant) (Respondent) Assessee By : Shri Sanjiv Sapra, Ar Revenue By : Shri Dharam Veer Singh, Cit Dr Date Of Hearing : 30.07.2025 Date Of Order : 15.10.2025 Order Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against Assessment Order Dated 31.12.2015 Passed By The Assessment Unit, Income Tax Department Under Section 143(3) Read With Section 144C(13)R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2021-22 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act. 2. M/S. Assimilate Solutions India Private Limited, The Assessee Was Incorporated On 19.04,2012 & Is Engaged In The Business Of Providing

For Appellant: Shri Sanjiv Sapra, ARFor Respondent: Shri Dharam Veer Singh, CIT DR
Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)

r.w.s. 144B of the Income-tax Act, 1961 (for short ‘the Act”) for Assessment Year 2021-22 pursuant to the directions of the Dispute Resolution Panel u/s 144C(5) of the Act. 2. M/s. Assimilate Solutions India Private Limited, the assessee was incorporated on 19.04,2012 and is engaged ... Income-tax Act, 1961 ('the Act') for the Assessment year 2021-22 in pursuance of the directions dated 30.08.2024 issued by Dispute Resolution Panel -1, New Delhi ('the DRP') under Section 144C(5) of the Act on the following grounds, which are independent and without prejudice to each other

Tupperware India Private Limited, Connaught Place New Delhi vs. National Faceless Assessment Centre Through Deputy Commissioner of Income Tax, Ip Estate New Delhi

The appeal is allowed partly

ITA 4475/DEL/2024[2020-21]Status: DisposedITAT Delhi15 Oct 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year : 2020-21

Section 143(3)Section 37Section 92BSection 92C

144C(13)r.w.s. 144B of the income-tax Act, 1961 pertaining to the assessment year 2020-21 in pursuance to directions of learned Dispute Resolution Panel (DRP). 2 2. The appeal of assesse raised following grounds; “General Grounds: 1. On the facts and circumstances of the case, the assessment order ... under section 143(3) r.w.s. 1440(13) r.w.s 144B of the Income-tax Act, 1961 (‘the Act’) after following directions of the Dispute Resolution Panel -I (‘Ld. DRP’) is bad in law and barred by limitation. 2. On the facts and circumstances of the case

DCIT, New Delhi vs. M/S. Vodafone Essar Digilink Ltd., New Delhi

ITA 1158/DEL/2015[2010-11]Status: DisposedITAT Mumbai14 Oct 2025AY 2010-11

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Ketan Ved & Shri Ninad PatadeFor Respondent: Shri Pankaj Kumar
Section 143(1)Section 143(3)Section 144C(1)Section 144C(5)Section 92C

hereinafter referred to as ‘the ITA No.1073/Del/2015 & ITA No.1158/Del/2015 Assessment Year 2010-2011 Act’], as per the directions issued by Dispute Resolution Panel –II, New Delhi [for short ‘DRP’], on 18/12/2014 under Section 144C(5) of the Act. 1.1. The facts in brief are that the Assessee-Company filed return ... commission expense on ad hoc basis, which resulted into disallowance amounting to Rs. 14,23,29,976/-. The assessee approached the Dispute Resolution Panel (DRP) against the addition in the draft order. The DRP got convinced with the assessee's contention and, relying on the order passed for the A.Ys

Vodafone Digilink Limited, New Delhi vs. Deputy Commissioner of Income-Tax, New Delhi

ITA 1073/DEL/2015[2010-11]Status: DisposedITAT Mumbai14 Oct 2025AY 2010-11
Section 143(1)Section 143(3)Section 144C(1)Section 144C(5)Section 92C

read with Section 143(3) of the Income Tax Act, 1961 [hereinafter referred to as 'the Act'], as per the directions issued by Dispute Resolution Panel –II, New Delhi [for short 'DRP'], on 18/12/2014 under Section 144C(5) of the Act. 1. 1. The facts in brief are that ... commission expense on ad hoc basis, which resulted into disallowance amounting to Rs. 14,23,29,976/-. The assessee approached the Dispute Resolution Panel (DRP) against the addition in the draft order. The DRP got convinced with the assessee's contention and, relying on the order passed for the A.Ys

Steelwill Globotech Private Limited, Faridabad, Haryana vs. Income Tax Officer, Ward 1(4), Faridabad, Haryana

In the result, ground nos

ITA 1466/DEL/2025[2018-19]Status: DisposedITAT Delhi14 Oct 2025AY 2018-19
For Appellant: Shri Nikhil Goyal (Through VC), &For Respondent: Shri M.S Nethrapal, CIT(DR)
Section 144CSection 147Section 148Section 148ASection 92C

Airways (I) Ltd., 195 Taxman 117 (Bombay). 3. Per contra, Shri M.S Nethrapal representing the department submitted that the Dispute Resolution Panel (DRP) has granted substantial relief to the assessee and now the assessee is in appeal against the small quantum of addition of Rs.9,03,814/-. Once the assessee ... vide order dated 30.01.2024 passed u/s. 92CA(3) of the Act. The assessee filed objections against the said draft assessment order before the Dispute Resolution Panel (DRP). The DRP vide directions dated 30.11.2024 granted part relief to the assessee and sustained addition with respect to interest on loan advances

Warner Bros Distributing Inc., United States of America vs. The Assistant Commissioner of Income Tax, Circle International Taxation 4(3)(2), Mumbai

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

ITA 3411/MUM/2023[AY 2020-21]Status: DisposedITAT Mumbai13 Oct 2025

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Deepak Chopra (virtually present)For Respondent: Shri Satya Pal Kumar, CIT (DR)
Section 143(3)Section 144CSection 144C(5)Section 9(1)(vi)

section 143(3) read with section 144C of the Income Tax Act, 1961 (“the Act”) pursuant to the directions issued by the learned Dispute Resolution Panel - 2, Mumbai, [“learned DRP”] under section 144C(5) of the Act, for the assessment year 2020-21. 2. In this appeal, the assessee

Franklin Templeton Internaitoanl Services (I) P.Ltd, Mumbai vs. DCIT (OSD) 3(1), Mumbai

In the result the appeal filed by the assessee for assessment year 2007-08 and 2008-09 stands partly allowed

ITA 7216/MUM/2012[2008-09]Status: DisposedITAT Mumbai13 Oct 2025AY 2008-09

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 133(6)Section 92D

following grounds of appeal: Assessment year 2007-08 “1. On the facts and in the circumstances of the case, the Hon'ble Dispute Resolution Panel ('DRP") erred on facts and in law in confirming the action of the learned Transfer Pricing Officer ('TPO') and the learned Assessing Officer ... circumstances of the case, the learned Transfer Pricing Officer ("TPO') and the learned Assessing Officer (AO') under the directions of the Hon'ble Dispute Resolution Panel ('DRP") erred on facts and in law in making an addition of Rs.8,24,48,689 to the ITES transaction of the Appellant based

Franklin Templeton International Services (I) P. Ltd, Mumbai vs. Asst CIT 3(1)(OSD), Mumbai

In the result the appeal filed by the assessee for assessment year 2007-08 and 2008-09 stands partly allowed

ITA 6986/MUM/2011[2007-08]Status: DisposedITAT Mumbai13 Oct 2025AY 2007-08

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 133(6)Section 92D

following grounds of appeal: Assessment year 2007-08 “1. On the facts and in the circumstances of the case, the Hon'ble Dispute Resolution Panel ('DRP") erred on facts and in law in confirming the action of the learned Transfer Pricing Officer ('TPO') and the learned Assessing Officer ... circumstances of the case, the learned Transfer Pricing Officer ("TPO') and the learned Assessing Officer (AO') under the directions of the Hon'ble Dispute Resolution Panel ('DRP") erred on facts and in law in making an addition of Rs.8,24,48,689 to the ITES transaction of the Appellant based

Lear Automotive India P. Ltd., Pune vs. Assistant Commissioner of Income Tax, Circle-8, Pune

ITA 554/PUN/2024[2016-17]Status: DisposedITAT Pune10 Oct 2025AY 2016-17
For Appellant: Shri Dhanesh Bafna &For Respondent: Shri Prakash L. Pathade
Section 143(3)Section 144C(13)Section 144C(5)Section 92C

Additional/Joint/Deputy/Assistant Commissioner of Income Tax/Income Tax Officer, National e-Assessment Center, Delhi (“Ld. AO”) in pursuance of the directions issued by Dispute Resolution Panel-3, Mumbai (“Ld. DRP") dated 26.12.2023 u/s 144C(5) of the Income Tax Act, 1961 (the “Act”) pertaining to Assessment Year ("AY") 2016-17. 2. This ... order u/s 144C(13) of the Income Tax Act, 1961 (the “Act”) dated 22.12.2019 against which the assessee filed objection before the Ld. Dispute Resolution Panel (“DRP”). However, the assessee's objections were rejected by the Ld. DRP vide its order dated 22.03.2021. Pursuant thereto, the final assessment order

Atos Information Technologies Hk Limited, Mumbai vs. Deputy Commissioner of Income Tax (Int Tax)-1(1)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 4708/MUM/2023[2021-22]Status: DisposedITAT Mumbai10 Oct 2025AY 2021-22

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Ms. Chandani Shah a/w Ms. Tejal Saraf &For Respondent: Shri Satya Pal Kumar - CIT D/R
Section 143(2)Section 143(3)Section 144C(13)Section 234ASection 234BSection 270ASection 9

quashed. 3. On the facts and in the circumstances of the case and in law, the Ld. AO and the Ld. Dispute Resolution Panel ('the DRP') erred in holding that the receipts of Rs. 85,63,75,446/- are in the nature of 'Royalty' under Section

Bmc Software Asia Pacific Pte Ltd, Singapore vs. Assistant Commissioner of Income Tax, Pune

In the result, appeal of the assessee is partly allowed

ITA 329/PUN/2025[2022-2023]Status: DisposedITAT Pune09 Oct 2025AY 2022-2023

Bench: or at, the time of hearing of the appeal, so as to enable the Honourable income-tax Appellate Tribunal to decide this appeal according to law." Findings & Analysis : 2. We have heard both the parties, perused the records. Assessee is Tax Resident of Singapore and it is engaged in selling Software Products to end use customers, including customers in India. It is mentioned in the Assessment Order that Assessee has also provided IT Support and Maintenance Services with reference to such softw

Section 115ASection 143(3)Section 144C(5)Section 270ASection 274Section 9(1)(vii)

assessee against the Assessment Order under section 143(3) r.w.s 144C(13) of the Act, 1961 dated 26.12.2024 for A.Y.2022-23 emanating from Dispute Resolution Panel’s order passed under section 144C(5) of the Act, dated 12.11.2024 and Draft Assessment Order passed under section ITA No.329/PUN/2025 [A] 144C ... thus as per Article 12 of the India- Singapore DTAA i.e. @10%.” 4. Aggrieved by the Draft Assessment Order, Assessee filed objections before Dispute Resolution Panel(DRP). Assessee submitted before DRP an elaborate submission. Assessee also 3 ITA No.329/PUN/2025 [A] submitted before DRP that the issue is covered in favour

B & R Industrial Automation Pvt. Ltd., Pune vs. DCIT, Circle 1(1), Pune

ITA 2469/PUN/2024[2021-22]Status: DisposedITAT Pune09 Oct 2025AY 2021-22

Bench: SHRI VINAY BHAMORE (Judicial Member)

Section 143(3)Section 144C

order of Assessing Officer(Assessment Unit) passed under section 143(3) r.w.s 144C(13) r.w.s 144B of the Act, dated 26.09.2024 emanating from Dispute Resolution Panel’s order under section 144C of the Act, ITA No.2469/PUN/2024 [A] dated 06.09.2024 emanating from Draft Assessment Order dated 22.12.2023. The Grounds of appeal ... trading upon total sales more than 75%. Thus, this filter was applied by TPO himself. 7.1 Regarding Maxim SMT Technologies Private Limited, the Dispute Resolution Panel has mentioned as under on page 16 of the order : “Trading Turnover” filter : 8 ITA No.2469/PUN/2024 [A] As per the applicant, the trading proportions

Invesco (India) Private Limited, Hyderabad vs. DCIT., Circle 2(1), Hyderabad

ITA 1320/HYD/2024[2021-22]Status: DisposedITAT Hyderabad08 Oct 2025AY 2021-22

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.1320/Hyd/2024 (निर्धारण वर्ष/Assessment Year: 2021-22) Invesco (India) (P) Ltd Vs. Hyderabad Dy.Cit Circle 2(1) Hyderabad (Respondent) Pan:Aacch8216L (Appellant) निर्धारिती द्वारा / Assessee By: Cas Shri K.C.Devdas, Kranthi Pallivelu & Mrudulatha राजस्व द्वारा / Revenue By:: Dr. Narendra Kumar Naik, Cit(Dr) सुनवाई की तारीख / Date Of Hearing: 10/09/2025 घोषणा की तारीख / Pronouncement: 08/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By M/S. Invesco (India) (P) Ltd, (“The Assessee”), Feeling Aggrieved By The Assessment Order Pass By The Learned Assessing Officer (“Ld. Ao") U/S 143(3) R.W.S. 144C(13) R.W.S 144B Of The Income Tax Act (“ The Act”), Dated 29.10.2024 For The A.Y 2021-22.

For Appellant: CAs Shri K.C.Devdas, KranthiFor Respondent: : Dr. Narendra Kumar Naik
Section 143(3)Section 144BSection 144C(13)

Deputy Commissioner of Income Tax, Circle 2(1), Hyderabad ('Ld. AO') in pursuance of the directions issued by the Hon'ble Dispute Resolution Panel - I, Bengaluru ('Hon'ble DRP') on the following grounds: On the facts and circumstances of the case and contrary to law - 1. The Deputy Commissioner ... Deputy Commissioner of Income Tax, Circle 2(1), Hyderabad ('Ld. AO') in pursuance of the directions issued by the Hon'ble Dispute Resolution Panel - I, Bengaluru ('Hon'ble DRP') erred in making an addition of Rs.33,90,99,385/- (based on the provisions of chapter X of the Income

Deputy Commissioner, Mumbai vs. Gaurav Investments, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 5053/MUM/2025[2018-19]Status: DisposedITAT Mumbai08 Oct 2025AY 2018-19

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankardeputy Commissioner Of Income Tax, Room No.656, 6Th Floor, Aaykar Bhavan, Maharishi Karve Road, Mumbai - 400020 ............... Appellant V/S Gaurav Investments, 1St Floor, B & C Block, Tradelink, E-Wing, ……………… Respondent Kamala Mill Compounds, Senapati Bapat Marg Lower Parel, Mumbai – 400023 Pan: Aadfg0064D

For Appellant: Shri Kshitiji Kasi ViswanathFor Respondent: Shri Swapnil Choudhary, Sr. DR
Section 143(3)Section 154Section 250Section 43C

addition of the above sum by invoking the provisions of section 43CA of the act. This was also upheld by the learned dispute resolution panel. 038. The learned authorized representative submitted that first proviso to section 43CA (1) of the act states that where the difference between the sale consideration