← All Phrases

“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

DCIT, New Delhi vs. Eicr (Cyprus) Ltd., New Delhi

ITA 5332/DEL/2015[2010-11]Status: DisposedITAT Delhi19 Sept 2025AY 2010-11

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

Section 124(4)Section 132Section 144CSection 147Section 148Section 151Section 6(3)(ii)

dismissal of the Revenue's SLP (C) [CC No. 16694/2013] on 27th September, 2013. 13. In Vijay Television (P) Ltd. v. Dispute Resolution Panel [2014] 369 ITR 113 (Mad.), a similar question arose. There, the Revenue sought to rectify a mistake by issuing a corrigendum after the final assessment order ... Zuari Cement Ltd. v. ACIT (supra) and a number of other decisions, the Madras High Court in Vijay Television (P) Ltd. v. Dispute Resolution Panel (supra) quashed the final order of the AO and the demand notice. Interestingly, even as regards the corrigendum issued, the Madras High Court held that

DCIT, New Delhi vs. Bennett Williamson Engineers Ltd., New Delhi

ITA 4056/DEL/2015[2011-12]Status: DisposedITAT Delhi19 Sept 2025AY 2011-12

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

Section 132Section 153Section 153CSection 6(3)(ii)Section 9(1)

dismissal of the Revenue's SLP (C) [CC No. 16694/2013] on 27th September, 2013. 13. In Vijay Television (P) Ltd. v. Dispute Resolution Panel [2014] 369 ITR 113 (Mad.), a similar question arose. There, the Revenue sought to rectify a mistake by issuing a corrigendum after the final assessment order ... Zuari Cement Ltd. v. ACIT (supra) and a number of other decisions, the Madras High Court in Vijay Television (P) Ltd. v. Dispute Resolution Panel (supra) quashed the final order of the AO and the demand notice. Interestingly, even as regards the corrigendum issued, the Madras High Court held that

DCIT, New Delhi vs. Bennett Williamson Engineers Ltd., New Delhi

In the result, the appeals of the Revenue in ITA Nos

ITA 4055/DEL/2015[2010-11]Status: DisposedITAT Delhi19 Sept 2025AY 2010-11

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

Section 132Section 153Section 153CSection 6(3)(ii)Section 9(1)

dismissal of the Revenue's SLP (C) [CC No. 16694/2013] on 27th September, 2013. 13. In Vijay Television (P) Ltd. v. Dispute Resolution Panel [2014] 369 ITR 113 (Mad.), a similar question arose. There, the Revenue sought to rectify a mistake by issuing a corrigendum after the final assessment order ... Zuari Cement Ltd. v. ACIT (supra) and a number of other decisions, the Madras High Court in Vijay Television (P) Ltd. v. Dispute Resolution Panel (supra) quashed the final order of the AO and the demand notice. Interestingly, even as regards the corrigendum issued, the Madras High Court held that

DCIT, New Delhi vs. Gainway Holdings Ltd., New Delhi

In the result, the appeal of the Revenue in ITA No

ITA 4007/DEL/2015[2009-10]Status: DisposedITAT Delhi19 Sept 2025AY 2009-10

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Dcit Gainway Holdings Ltd. Vs Central Circle-19, Room C/O. Sandeep Chilana, Advocate No. 362, Ara Centre, E-2, Chilana & Chilana Law Offices, Jhandewalan Extension, Advoate For The Respondent C- New Delhi 56, Lfg, Jangpura Extention, New Delhi-110014 Pan: Aafcg6056L Appellant Respondent

Section 132Section 153CSection 6(3)(ii)Section 9(1)

dismissal of the Revenue's SLP (C) [CC No. 16694/2013] on 27th September, 2013. 13. In Vijay Television (P) Ltd. v. Dispute Resolution Panel [2014] 369 ITR 113 (Mad.), a similar question arose. There, the Revenue sought to rectify a mistake by issuing a corrigendum after the final assessment order ... Zuari Cement Ltd. v. ACIT (supra) and a number of other decisions, the Madras High Court in Vijay Television (P) Ltd. v. Dispute Resolution Panel (supra) quashed the final order of the AO and the demand notice. Interestingly, even as regards the corrigendum issued, the Madras High Court held that

DCIT, New Delhi vs. Gynia Holding Ltd., New Delhi

In the result, the appeals of the Revenue in ITA Nos

ITA 3916/DEL/2015[2011-12]Status: DisposedITAT Delhi19 Sept 2025AY 2011-12

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

Section 132Section 153CSection 6(3)Section 6(3)(ii)Section 9(1)

dismissal of the Revenue's SLP (C) [CC No. 16694/2013] on 27th September, 2013. 13. In Vijay Television (P) Ltd. v. Dispute Resolution Panel [2014] 369 ITR 113 (Mad.), a similar question arose. There, the Revenue sought to rectify a mistake by issuing a corrigendum after the final assessment order ... Zuari Cement Ltd. v. ACIT (supra) and a number of other decisions, the Madras High Court in Vijay Television (P) Ltd. v. Dispute Resolution Panel (supra) quashed the final order of the AO and the demand notice. Interestingly, even as regards the corrigendum issued, the Madras High Court held that

DCIT, New Delhi vs. Gynia Holding Ltd., New Delhi

In the result, the appeals of the Revenue in ITA Nos

ITA 3915/DEL/2015[2010-11]Status: DisposedITAT Delhi19 Sept 2025AY 2010-11

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

Section 132Section 153CSection 6(3)Section 6(3)(ii)Section 9(1)

dismissal of the Revenue's SLP (C) [CC No. 16694/2013] on 27th September, 2013. 13. In Vijay Television (P) Ltd. v. Dispute Resolution Panel [2014] 369 ITR 113 (Mad.), a similar question arose. There, the Revenue sought to rectify a mistake by issuing a corrigendum after the final assessment order ... Zuari Cement Ltd. v. ACIT (supra) and a number of other decisions, the Madras High Court in Vijay Television (P) Ltd. v. Dispute Resolution Panel (supra) quashed the final order of the AO and the demand notice. Interestingly, even as regards the corrigendum issued, the Madras High Court held that

DCIT, New Delhi vs. Gynia Holding Ltd., New Delhi

In the result, the appeals of the Revenue in ITA Nos

ITA 3914/DEL/2015[2009-10]Status: DisposedITAT Delhi19 Sept 2025AY 2009-10

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

Section 132Section 153CSection 6(3)Section 6(3)(ii)Section 9(1)

dismissal of the Revenue's SLP (C) [CC No. 16694/2013] on 27th September, 2013. 13. In Vijay Television (P) Ltd. v. Dispute Resolution Panel [2014] 369 ITR 113 (Mad.), a similar question arose. There, the Revenue sought to rectify a mistake by issuing a corrigendum after the final assessment order ... Zuari Cement Ltd. v. ACIT (supra) and a number of other decisions, the Madras High Court in Vijay Television (P) Ltd. v. Dispute Resolution Panel (supra) quashed the final order of the AO and the demand notice. Interestingly, even as regards the corrigendum issued, the Madras High Court held that

DCIT, New Delhi vs. Focusoil Inc., New Delhi

In the result, the appeal of the Revenue in ITA No

ITA 3911/DEL/2015[2009-10]Status: DisposedITAT Delhi19 Sept 2025AY 2009-10

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Dcit Vs Focusoil Inc. Central Circle-19, Room C/O. Sandeep Chilana, Advocate No. 362, Ara Centre, E-2, Chilana & Chilana Law Offices, Jhandewalan Extension, Advoate For The Respondent C- New Delhi 56, Lfg, Jangpura Extention, New Delhi-110014 Pan: Aaccf3908K Appellant Respondent

Section 132Section 153CSection 6(3)(ii)Section 9(1)

dismissal of the Revenue's SLP (C) [CC No. 16694/2013] on 27th September, 2013. 13. In Vijay Television (P) Ltd. v. Dispute Resolution Panel [2014] 369 ITR 113 (Mad.), a similar question arose. There, the Revenue sought to rectify a mistake by issuing a corrigendum after the final assessment order ... Zuari Cement Ltd. v. ACIT (supra) and a number of other decisions, the Madras High Court in Vijay Television (P) Ltd. v. Dispute Resolution Panel (supra) quashed the final order of the AO and the demand notice. Interestingly, even as regards the corrigendum issued, the Madras High Court held that

Technip India Limited, New Delhi vs. ACIT, Spl Range-9, New Delhi

In the result, Appeal No.6390/Del/2017 is partly allowed as per above terms

ITA 9852/DEL/2019[2015-16]Status: DisposedITAT Delhi17 Sept 2025AY 2015-16

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 6390/Del/2017 Assessment Year: 2013-14 Ita No. 9852/Del/2019 Assessment Year: 2015-16 Technip Energies India Vs. Additional Commissioner Of Limited, ( Formerly Known As Income Tax, Technip India Limited), Special Range-9, A-4, Sector 1, Institutional New Delhi Area, Noida – 201 301 Pan No. Aaack3349R (Appellant) (Respondent)

For Appellant: Shri Vishal Kalra, Adv., Shri Yishu GoelFor Respondent: Shri Dharm Veer Singh, CIT (DR)
Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 250Section 92C

Adjustments of Rs. 30,33,721/-. 3.4 Aggrieved with the draft assessment order dated 29.12.2016 of Ld. AO, assessee approached Hon'ble Dispute Resolution Panel and raised objections to the proposed additions in the order. The Hon'ble DRP-2 under Section 144C(5) has given its directions through ... amount of outstanding receivables; 4. That on the facts and circumstances of the case and in law, the learned Dispute Resolution Panel ("DRP")/AO/TPO has erred in considering the amount of year end outstanding receivables from associated enterprises as an international transaction; 5. That on the facts and circumstances

Technip India Ltd., Noida vs. Addl.CIT, Special Range- 9, New Delhi

In the result, Appeal No.6390/Del/2017 is partly allowed as per above terms

ITA 6390/DEL/2017[2013-14]Status: DisposedITAT Delhi17 Sept 2025AY 2013-14

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 6390/Del/2017 Assessment Year: 2013-14 Ita No. 9852/Del/2019 Assessment Year: 2015-16 Technip Energies India Vs. Additional Commissioner Of Limited, ( Formerly Known As Income Tax, Technip India Limited), Special Range-9, A-4, Sector 1, Institutional New Delhi Area, Noida – 201 301 Pan No. Aaack3349R (Appellant) (Respondent)

For Appellant: Shri Vishal Kalra, Adv., Shri Yishu GoelFor Respondent: Shri Dharm Veer Singh, CIT (DR)
Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 250Section 92C

Adjustments of Rs. 30,33,721/-. 3.4 Aggrieved with the draft assessment order dated 29.12.2016 of Ld. AO, assessee approached Hon'ble Dispute Resolution Panel and raised objections to the proposed additions in the order. The Hon'ble DRP-2 under Section 144C(5) has given its directions through ... amount of outstanding receivables; 4. That on the facts and circumstances of the case and in law, the learned Dispute Resolution Panel ("DRP")/AO/TPO has erred in considering the amount of year end outstanding receivables from associated enterprises as an international transaction; 5. That on the facts and circumstances

Andante Foods LLP, Bangalore vs. Deputy Commissioner of Income Tax, Circle-1(1)(1), Bengaluru

Appeal are allowed, and appeal of the assessee is allowed for statistical purposes

ITA 1723/BANG/2024[2020-21]Status: DisposedITAT Bangalore15 Sept 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2020-21

For Respondent: Shri Harsha M., CA
Section 143(2)Section 143(3)Section 144C(1)Section 92C

144C(1) of the Act dated Page 2 of 12 21.9.2023 and TP order u/s. 92CA(3) dated 27.6.2023 and directions of the Dispute Resolution Panel-1, Bengaluru [ld. DRP] dated 6.6.2024. 2. The assessment order contains the upward revision of the arm’s length price [ALP] of the international

Factive Limited, Mumbai vs. Assistant Commissioner of Income Tax, (International Taxation )-2(3)(1), Mumbai

In the result, both the appeals are partly allowed

ITA 4706/MUM/2023[2021-22]Status: DisposedITAT Mumbai15 Sept 2025AY 2021-22

Bench: Shri Saktijit Dey & Shri Girish Agrawal & Factive Limited Asst. Cit(It)-2(3)(1) C/O. Price Waterhouse & Co. Llp 609, 6Th Floor, Kautilya Bhavan, 252, Veer Savarkar Marg, C-41, C-43, G Block, Vs. Shivaji Park, Dadar, Bandra Kurla Complex, Mumbai-400 028 Bandra (E), Mumbai Pan/Gir No. Aaccf 5745 J (Appellant) : (Respondent) : Shri Dhanesh Bafna A/W Appellant By Shri Yogesh Malpani & Ms. Kinjal Patel Respondent By : Shri Krishna Kumar (Sr. Dr) Date Of Hearing : 21.08.2025 Date Of Pronouncement : 15.09.2025 O R D E R Per Saktijit Dey: Captioned Appeals By The Assessee Are Against The Final Assessment Orders Passed U/S. 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 (‘The Act’ For Short), In Pursuance To The Directions Of Learned Dispute Resolution Panel (‘Ld. Drp' For Short) & Pertains To The Assessment Years (A.Y.) 2021-22 & 2022-23. 2. Since The Substantive Issue On Merits, Arising In The Appeals Are More Or Less Common In Both The Appeals, We Propose To Take Up Ita No. 4706/Mum/2023, Pertaining To A.Y. 2021-22, As The Lead Appeal. (A.Ys. 2021-22 & 2022-23) Factive Limited Vs. Asst. Cit(It) 3. Ground Nos. 1, 2 & 3 Are Basically On Legal Issues, Challenging The Validity Of The Final Assessment Order. At The Outset, Ld. Counsel Appearing For The Assessee Submitted That He Would Prefer To Address The Issues On Merits And, If Warranted, May Press The Legal Grounds.

For Respondent: Shri Krishna Kumar (Sr. DR)
Section 143(3)Section 9(1)(vi)

r.w.s 144C(13) of the Income Tax Act, 1961 (‘the Act’ for short), in pursuance to the directions of learned Dispute Resolution Panel (‘ld. DRP' for short) and pertains to the assessment years (A.Y.) 2021-22 and 2022-23. 2. Since the substantive issue on merits, arising in the appeals

Sanjay Mehta, Jaipur vs. DCIT Circle (Intl Tax), Jaipur

ITA 201/JPR/2025[2018-19]Status: DisposedITAT Jaipur12 Sept 2025AY 2018-19
For Appellant: Shri Rohan Sogani, C.AFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 132Section 144C(5)Section 153CSection 69B

Assessment Year 2018–19. In both such appeals, the respective orders of assessment were passed, by AO, after considering the directions of the Dispute Resolution Panel (“DRP”) issued separately for both the assessees, under Section 144C(5) of the Act dated 19.12.2024. 2.1 In appeal of Sanjay Mehta ... quashed as being illegal and void ab initio. 2. In the facts and circumstances of the case and in law, the ld. Dispute Resolution Panel ("DRP") erred in giving directions to the ld. AO for making additions of Rs. 69,32,250/- to the income of the assessee under Section

Urvashi Mehta, Jaipur vs. DCIT Circle (Intl Tax), Jaipur

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

ITA 200/JPR/2025[2018-19]Status: DisposedITAT Jaipur12 Sept 2025AY 2018-19
For Appellant: Shri Rohan Sogani, C.AFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 132Section 144C(5)Section 153CSection 53CSection 69B

Assessment Year 2018-19. In both such appeals, the respective orders of assessment were passed, by AO, after considering the directions of the Dispute Resolution Panel (“DRP’’) issued separately for both the assessees, under Section 144C(5) of the Act dated 19.12.2024. 2.1. In appeal of Sanjay Mehta ... quashed as being illegal and void ab initio. 2. In the facts and circumstances of the case and in law, the ld. Dispute Resolution Panel ("DRP") erred in giving directions to the ld. AO for making additions of Rs. 69,32,250/- to the income of the assessee under Section

Philips International B.V, Kolkata vs. ACIT(I.T), Cir-2(1), Kolkata.

In the result, appeal of the assessee is allowed

ITA 555/KOL/2023[2020-21]Status: DisposedITAT Kolkata12 Sept 2025AY 2020-21

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm M/S Philips International B.V. Asst. Commissioner Of Income C/O Deloitte Haskins & Sells Llp, Tax (International Taxation), Bengal Intelligent Park, Building Circle 2(1), Kolkata Omega, 13Th & 14Th Floor, Room No. 210, 2 Nd Floor, Vs. Block-Ep & Gp, Sector-V Salt Aaykar Bhavan, Poorva, 110, Lake Electronic Complex, Shanti Pally, Kolkata-700107 Kolkata-700091 West Bengal (Appellant) (Respondent) Pan No. Aafcp4065J Assessee By : Shri Ketan K. Ved, Ar Revenue By : Shri S.B. Chakraborthy, Dr Date Of Hearing: 18.07.2025 Date Of Pronouncement: 12.09.2025

For Appellant: Shri Ketan K. Ved, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 143(3)Section 144CSection 282(2)

Rajesh Kumar, AM: This is an appeal preferred by the assessee against the order of the ld. Dispute Resolution Panel, Delhi (hereinafter referred to as the “Ld. DRP”] for AY 2020-21. 02. The only issue pressed by the ld. Counsel for the assessee is against the final invalid order

Apollo Tyres Ltd., Cochin vs. DCIT Corporate Cir 1(1), Kochi

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

ITA 679/COCH/2024[2020-21]Status: DisposedITAT Cochin10 Sept 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2020-21 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Acit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 10.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 115JSection 143(3)Section 154Section 35Section 92C

receipt of the draft assessment order, the appellant company filed objections before the Dispute Resolution Panel (DRP) contesting all the above additions. The DRP partly allowed objections. 6. On receipt of the directions from the DRP, the AO had passed the final assessment order dated 20.06.2024 passed ... dated 20th June, 2024, by the Assessment Unit, Income Tax Department (AO') pursuant to the directions of the Dispute Resolution Panel ('DRP'), and the additions/disallowances made by the Id. AO/TPO, are grossly injudicious, unwarranted, against the facts of the case and bad in law. 2. The additions/disallowances made are unsustainable

Apollo Tyres Ltd, Cochin vs. The Deputy Commissioner of Income Tax, Cochin

In the result, this ground of appeal stands allowed

ITA 1000/COCH/2024[2021-22]Status: DisposedITAT Cochin10 Sept 2025AY 2021-22

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2021-22 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Acit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 10.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 14ASection 92C

Addition u/s. 14A Rs. 12,22,000/- 5. On receipt of the draft assessment order, the appellant company filed objections before the Dispute Resolution Panel (DRP) contesting all the above additions. The DRP dismissed the objections vide order dated 04.09.2024. 3 Apollo Tyres Ltd. 6. On receipt of the directions ... dated 24th October, 2024, by the Assessment Unit, Income Tax Department (AO) pursuant to the directions of the Dispute Resolution Panel (DRP'), and the additions/disallowances made by the Id. AO/Transfer Pricing Officer (TPO), are grossly injudicious, unwarranted, against the facts of the case and bad in law. 2. The additions/disallowances

Orbis Real Estate Fund I, Hyderabad (Auth. Rep.) vs. ADIT (International Taxation)-2 - 2, Hyderabad

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

ITA 785/HYD/2024[2020-2021]Status: DisposedITAT Hyderabad10 Sept 2025AY 2020-2021

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri Sai Sourabh K, C.AFor Respondent: Dr. Narender Kumar Naik
Section 143(3)Section 154

r.w.s. 144C(13) of the Income Tax Act, 1961 (“the Act”) dated 30.06.2023 as per ITA No.785/Hyd/2024 2 the direction of Learned Dispute Resolution Panel-1, Bangalore (“Ld. DRP”) dated 30.05.2023 for the A.Y. 2020-21. 2. At the outset, it is noted that there is a delay

Netradyne Technology India Private Limited, Bengaluru vs. Income Tax Officer, Ward-5(1)(1), Bengaluru

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

ITA 2258/BANG/2024[2021-22]Status: DisposedITAT Bangalore10 Sept 2025AY 2021-22

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2021-22

For Appellant: Shri Suresh Muthukrishnan, ARFor Respondent: Dr. Divya K J, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144Section 92C

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL

Gemological Institute of America, Inc., United States vs. The Assistant Commissioner of Income-Ta (International Taxation) - Circle 2(3)(2), Mumbai

In the result, appeals of the assesse are allowed partly for statistical

ITA 1293/MUM/2025[2022-23]Status: DisposedITAT Mumbai09 Sept 2025AY 2022-23

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Anikesh Banerjee, Hon'Ble

For Appellant: Shri J.D. Mistry, Sr. Adv. & Shri Niraj Sheth, A/RsFor Respondent: Shri Satya Pal Kumar, CIT D/R a/w Shri Krishna Kumar, Sr. D/R
Section 144C(13)Section 147Section 148

sake of convenience and brevity. 3. The common grievance read as under:- "1: 0 Re.: General: 1: 1 The Assessing Officer / the Dispute Resolution Panel have erred in assessing the total income of the Appellant at Rs.5,18,83,68,139/- against the returned income of Rs.4 ... appeal at or before the hearing of the appeal. 2: 0 Re: Validity of re-assessment proceedings: 2: 1 The Assessing Officer / the Dispute Resolution Panel has erred in re-opening the Appellants assessment u/s.148 of the Income-tax Act, 1961. 2: 2 The Appellant submits that considering the facts