“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

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

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

ITA 1292/MUM/2025[2019-20]Status: DisposedITAT Mumbai09 Sept 2025AY 2019-20

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 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

Gemological Research (Thailand) Co. Ltd., Thailand vs. The Assistant Commissioner of Income-Tax (International Taxation) - Circle 2(3)(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 1291/MUM/2025[2019-20]Status: DisposedITAT Mumbai09 Sept 2025AY 2019-20

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

For Appellant: Shri Satya Pal Kumar, CIT D/R a/w Shri Krishna Kumar, Sr. D/R

Section 147Section 148

grievance of the assessee reads as under:- “1: 0 Re: Validity of re-assessment proceedings: 1: 1 The Assessing Officer / the Dispute Resolution Panel has erred in re-opening the Appellant's assessment u/s. 148 of the Income-tax Act, 1961 ("Act"). 1:2 The Appellant submits that considering ... prejudice to the foregoing: 2: 0 Re.: Holding that the Appellant has a 'Permanent Establishment' ("PE") in India:: 2:1 The Assessing Officer/the Dispute Resolution Panel has erred in holding that the Appellant has a 'Permanent Establishment' ("PE") in India. 2:2 The Appellant submits that considering the facts

Ust Global Technology Services (India) Private Limited, Kochi vs. DCIT, Corporate Circle 2(1), Kochi

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

ITA 1071/COCH/2024[2021-22]Status: DisposedITAT Cochin08 Sept 2025AY 2021-22

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary

For Appellant: Respondent byFor Respondent: Shri Rajakannam, Advocate

Section 143Section 92C

receipt of draft assessment order, several objections were raised by the appellant before the Dispute Resolution Panel (DRP). The DRP had dismissed all the objections raised by the appellant. After receipt of the directions issued by the DRP, the final assessment order was passed vide order dated 23/10/2024 passed

M/S.Joy Alukkas India P. Ltd, Cochin vs. The ACIT, Cochin

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

ITA 38/COCH/2017[2012-13]Status: DisposedITAT Cochin08 Sept 2025AY 2012-13

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)

For Appellant: Smt. Parvathy Ammal, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 143(3)Section 36(1)(iii)Section 36(1)(viii)Section 92C

expenses of Rs. 1,05,59,467/-. 8. On receipt of draft assessment order, the appellant-company had filed several objections before the Dispute Resolution Panel-2, Bangalore (DRP). The DRP issued directions confirming the addition of TP adjustments and further directed to allow the expenditure incurred on improvements ... transactions are entered with an associated enterprises, went on to confirm that the transactions were falling within section 92B(2). 3. The Dispute Resolution Panel is not justified in not passing any adjudication on the grounds raised by the appellant that AIRas was not an associated enterprises falling with section

M/S.Joy Alukkas India P. Ltd, Trichur vs. The ACIT, Ernakulam

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

ITA 119/COCH/2016[2011-12]Status: DisposedITAT Cochin08 Sept 2025AY 2011-12

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)

For Appellant: Smt. Parvathy Ammal, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 143(3)Section 36(1)(iii)Section 36(1)(viii)Section 92C

Lowes Services India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle 4(1)(1), Bangalore

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

ITA 1734/BANG/2024[AY 2020-21]Status: DisposedITAT Bangalore08 Sept 2025

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

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

Section 143(1)Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 36(1)(va)Section 80G

with section 144C(13) read with section 144C of the Act in pursuance of the Page 2 of 15 directions issued by the Dispute Resolution Panel — 1 (hereinafter referred to as the " Ld. DRP), Bengaluru dated 07 June 2024 under section 144C(5), of the Income ... against the returned income of Rs.78,61,52,120. 9. The assessee aggrieved with the same preferred objections before the ld. Dispute Resolution Panel [ld. DRP], who passed the direction on 7.6.2024. Based on this, the ld. TPO gave effect to the said direction vide order dated 8.7.2024 wherein

Virendra M Gaidhane, Mumbai vs. ITO, Ward 2(3)(1), Mumbai

In the result, assessee’s appeal in ground no-1 is allowed

ITA 64/MUM/2025[2022-23]Status: DisposedITAT Mumbai05 Sept 2025AY 2022-23

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Nishit Gandhi a/w Ms. Aadnya BhandariFor Respondent: Shri Krishna Kumar (SR DR)

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

ACIT, ITA No. 4546/mum/2024 date of pronouncement 01/04/2025 held that Final assessment order passed by Assessing Officer without following directions issued by Dispute Resolution Panel under section 144C is null and void and hence was to be quashed. 4. The Ld. DR argued and relied on the final assessment order

M/S Grob-Werke Gmbh & Co. Kg, Germany vs. The Assistant Commissioner of Income Tax, Intl Txn Circle, Vizag, Visakhapatnam

In the result, appeal of the assessee is partly allowed

ITA 176/VIZ/2025[2022-23]Status: DisposedITAT Visakhapatnam04 Sept 2025AY 2022-23

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.176/Viz/2025 (निर्धारण वर्ा/ Assessment Year:2022-23) Vs. M/S. Grob – Werke Gmbh & Co. Kg Acit Industriestrasse 4, 87719 Mindelheim International Taxation Circle Income Tax Office Germany, Pincode - 87719 Infinity Towers Sankaramatam Road [Pan:Aaifg4270G] Visakhapatnam - 530016 करदाता का प्रतततितित्व/ Assessee Represented By : Shri Nikhil Ajit Mutha, Ca : Shri Badicala Yadagiri, Cit(Dr) राजस्व का प्रतततितित्व/ Department Represented By सुिवाई समाप्त होिे की ततति/ Date Of Conclusion Of Hearing : 07.08.2025 घोर्णध की तधरीख/Date Of Pronouncement : 04.09.2025

Section 115ASection 129Section 142(1)Section 143(2)Section 143(3)Section 195

I.T.A.No.176/VIZ/2025 M/s. GROB – WERKE GmbH & Co. KG 5. Assessee being aggrieved by the draft assessment order filed its objections before the Ld. Dispute Resolution Panel, Bangalore (in short “Ld.DRP”). The Ld.DRP while disposing off the objection raised by the assessee called for the Remand Report from

M/S. Hydro Bs India Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bengaluru

The appeal of the assessee is partly allowed

ITA 2117/BANG/2024[2020-21]Status: DisposedITAT Bangalore04 Sept 2025AY 2020-21

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

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

Section 143(3)Section 144CSection 92CSection 92C(3)(c)

assessment proceedings, transfer pricing adjustments of Rs.1,46,78,480/- is made as Page 2 of 14 per direction of the ld. Dispute Resolution Panel-1, Bengaluru [ld. DRP] dated 10.6.2024 wherein the assessee’s objection against the draft assessment order passed u/s. 144C of the Act dated 29.9.2023 pursuant

Syntel Solutions (India) P. Ltd, Pune vs. Asst CIT Cir 10, Pune

In the result, the appeal by the assessee is dismissed as withdrawn

ITA 1882/MUM/2017[2012-13]Status: DisposedITAT Mumbai04 Sept 2025AY 2012-13

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalsyntel Solutions (India) Pvt. Ltd., Ground Floor S2 Software, Block Plot No. B-1/B-2, Dehu Alandi Road Midc, Talwadi, Software Technology Park ............... Appellant Pune - 412114 Pan: Aadct5744N V/S

For Appellant: NoneFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(3)

r.w.s 144C(13) of the Income-tax Act, 1961 (“the Act”), pursuant to the directions dated 21/12/2016 issued by the learned Dispute Resolution Panel-3, Mumbai [“learned DRP”], for the assessment year 2012-13. 2 2. In this appeal, the assessee has filed a letter dated 22/08/2025 seeking permission

Microsoft Corporation (India) Pvt Ltd, Delhi vs. DCIT (16) (1) Delhi, Delhi

Appeal of the assessee is allowed

ITA 1862/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Sept 2025AY 2017-18

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Vikas Awasthy & Shri Brajesh Kumar Singhआअसं.1862/िद"ी/2022 (िन.व. 2017-18) Microsoft Corporation (India) P. Ltd., 807, New Delhi House, Barakhamba Road, New Delhi 110001 ...... अपीलाथ"/Appellant Pan: Aaacm-5586-C बनाम Vs. Deputy Commissioner Of Income-Tax, Circle 16(1), Central Revenue Building, ..... "ितवादी/Respondent Ip Estate, Delhi अपीलाथ" "ारा/ Appellant By : S/Shri Nageswar Rao, (Through Vc) & Parth, Advocates "ितवादी"ारा/Respondent By : Shri Rajesh Kumar, Cit- Dr सुनवाई क" ितिथ/ Date Of Hearing : 04/09/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 04/09/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 30.06.2022, 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. Shri Nageswar Rao, Appearing On Behalf Of The Assessee Submitted At The Outset That, At This Stage He Is Confining His Submissions To Ground No. 1 Of Appeal

For Appellant: S/Shri Nageswar Rao, (Through VC) &For Respondent: Shri Rajesh Kumar, CIT- DR

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

ground of limitation. 3. The ld. Counsel narrating relevant facts to the issue raised in ground no. 1 of appeal submits that the Dispute Resolution Panel (DRP) issued directions u/s. 144C(5) of the Act on 23.03.2022, the Assessing Officer (AO) passed final assessment order ... 28th September, 2021. The draft order was passed by National Faceless Assessment Centre, Delhi, which was objected to by the assessee before Dispute Resolution Panel-2, New Delhi (hereinafter ‘the DRP’). The DRP passed directions under Section 144C(5) of the Act vide order dated 23rd March, 2022. In view

Avaada Sataramh Private Limited, Noida Gautam Budha Nagar, Up vs. ITO 5(1)(1) G Budh Nagar, Noida, Up

In the result, the appeal being ITA No

ITA 4916/DEL/2024[2021-22]Status: DisposedITAT Delhi03 Sept 2025AY 2021-22

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR

Section 115BSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153

/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. Since the issues are common and the appeals are connected, hence the same are heard together and being

Avaada Sustainable Rjproject Private Limited, Gautam Budha Nagar, Up vs. ITO 5 (1)(1), G Budh Nagar, Noida, Up

In the result, the appeal being ITA No

ITA 4884/DEL/2024[2021-22]Status: DisposedITAT Delhi03 Sept 2025AY 2021-22

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR

Section 115BSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153

Hitachi Astemo Haryana Private Limited, Faridabad vs. Assistant Commissioner of Income Tax, Delhi

In the result, the Appeal of the Assessee is allowed

ITA 3353/DEL/2024[AY 2018-19]Status: DisposedITAT Delhi03 Sept 2025

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Hitachi Astemo Haryana Private Vs Assistant Commissioner Limited Of Income Tax, Circle Plot No. 23-32, Sector-58, 10(1), C. R. Building, Behind Jcb India Ltd, Ito, Ip Estate, Faridabad, Haryana, India New Delhi Pan: Aabce5725G Appellant Respondent Assessee By Ms. Ananya Kapoor, Adv Revenue By Sh. S. K. Jadhav, Cit- Dr Date Of Hearing 06/08/2025 Date Of Pronouncement 03 /09/2025 Order Per Yogesh Kumar, U.S. Jm: This Appeal Is Filed By The Assessee Pertaining To Assessment

Section 143(3)Section 144C(13)Section 153(5)Section 254Section 270ASection 92C

payment of royalty. As against the order of the TPO dated 27/07/2021, Assessee filed objection before the Dispute Resolution Panel (DRP). The DRP granted relief to the Assessee in so far as manufacturing segment of Rs. 5,44,33,729/- and sustained the order

Sfdc Ireland Limited, Delhi vs. Deputy Commissioner of Income-Tax- 3(1)(1) Intl Tax, Delhi

In the result, the appeal of assessee is allowed as above

ITA 1475/DEL/2025[2022-23]Status: DisposedITAT Delhi02 Sept 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 153

Delhi ("Ld. AO") and also the directions dated 19 December 2024 issued under section 144C(5) of the Act by the Ld. Dispute Resolution Panel ("DRP") for Assessment Year ("AY") 2022-23, are invalid, bad in law and are liable to be quashed. 1.1 On the facts

M/S.Apollo Tyres Ltd, Cochin vs. The Principal Commissioner of Incometax, Cochin

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

ITA 609/COCH/2017[2013-14]Status: DisposedITAT Cochin01 Sept 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2013-14 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Dcit, 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: 01.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 115JSection 143(3)Section 32Section 32(1)(iia)Section 35Section 43(1)Section 92C

book profit determined u/s. 115JB of the Act. 4. 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 issued directions on 04.09.2017 confirming the TP adjustments. However, the DRP had directed ... Income Tax Act, 1961('the Act') by 8 Apollo Tyres Ltd. the Assessing Officer (AO') pursuant to the directions of the Dispute Resolution Panel (DRP) and the additions/disallowances made by the AO are illegal, bad in law and without jurisdiction. 2. The additions/disallowances made are unsustainable, unjust, highly excessive

Ebix Travels Pvt. Ltd., New Delhi vs. DCIT, Circle 2(2)(1), Bangalore

In the result appeal of the assessee is partly allowed

ITA 47/BANG/2025[2021-22]Status: DisposedITAT Bangalore29 Aug 2025AY 2021-22

Bench: Shri Prashant Maharishi & Shri Soundararjan K

Section 143Section 144BSection 144CSection 234ASection 234BSection 32Section 92CSection 92D

disallowance of depreciation of ₹ 1,845,615 was added to the total income pursuant to the direction passed by The Dispute Resolution Panel 1, New Delhi (the learned DRP) dated 27/9/2024 in the draft assessment order passed on 26/12/2023 wherein the order under section 92CA (3) was passed ... draft assessment order the above adjustment was made. 14. Against the draft assessment order, the assessee preferred an objection before the learned dispute resolution panel who passed its direction on 27/9/2024 wherein the objection of the assessee. i. With respect to the arm's-length price of the international transaction

Future First Info Services Private Ltd., Delhi vs. AO Circle-7(1), Delhi

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

ITA 672/DEL/2022[2017-18]Status: DisposedITAT Delhi29 Aug 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

Section 143(3)Section 270ASection 92D

Income-tax, 1 Future First Info Services Pvt. Ltd. Transfer Pricing Officer-1(2)(2), New Delhi (Ld. TPO) and the Hon'ble Dispute Resolution Panel 1, New Delhi ('Hon'ble DRP') erred on facts and in law in: 1.1 making an adjustment ... dated 20 April 2021 was passed. The assessee filed the ‘Objection’ against the said draft assessment order before the Hon’ble Dispute Resolution Panel (‘DRP’), who issued directions vide order dated 14 January 2022, wherein contentions of the Ld. TPO were upheld. Hence, this appeal is before

Temenos Headquarters Sa, Chennai vs. Assistant Commissioner of Income Tax, Chennai

In the result, the appeals filed by the assessee for assessment years 2022-

ITA 558/CHNY/2025[2022-23]Status: DisposedITAT Chennai28 Aug 2025AY 2022-23

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 558/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2022-23 & S.A. No.: 50/Chny/2025 [In I.T.A. No.558/Chny/2025] धनिाजरण वर्ज/Assessment Year: 2022-23

For Appellant: Shri. R. Sivaraman, AdvocateFor Respondent: Ms. Sita Krisnamoorthy, JCIT

Section 143(2)Section 143(3)Section 144C(5)

under India-Switzerland DTAA. 6. Against the draft order u/s.143(3) r.w.s.144C(1) of the Act, the assessee filed an objections before the Dispute Resolution Panel (DRP) on 29.04.2024. The DRP after hearing the case, passed an order u/s.144C(5) of the Act dated 26.12.2024 upholding the draft assessment order

Vazhoor Sudarsanan Thampi, Thrissur vs. Income Tax Officer, (International Taxation), Ward-2(1), Bengaluru

Appeal is partly allowed

ITA 893/BANG/2025[2015-16]Status: DisposedITAT Bangalore28 Aug 2025AY 2015-16

Bench: Shri Prashant Maharishi & Shri Soundararajan Ka. Y. 2015-16 Appellant Respondent Vazhoor Sudarshanan The Income Tax Officer Thampi International Taxation Vazhoor House, Ward 2 (1) T C 5/1892Valappad Bangalore Vallapad Beach Thrissur Kerala 680567 Pan Afxpt6193D For Appellant Shri Sidhesh N Gadi, Ca For Respondent Dr. Divya K J Cit Dr Date Of Hearing 19-08-2025 Date Of Pronouncement 28-08-2025

Section 142Section 143Section 144Section 144CSection 147Section 148Section 148ASection 69

Income -Tax Act, 1961 (The Act) determining the total income at ₹ 2,20,00,000/-in pursuance of direction of The Dispute Resolution Panel – 2, Bangalore (The Learned DRP) Page 1 of 14 dated 27/11/2024 in draft assessment order passed by the AO under section 144C ... held that there is no reason to interfere with the order of the assessing officer. 9. On the direction of the learned dispute resolution panel, the learned assessing officer passed an assessment order under section 147 read with section 144 of the act on 12/12/2024 determining the total income