“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

Accenture Solutions Private Limited, Mumbai vs. Dy. Commissioner of Income Tax, Mumbai

In the result, the appeal is allowed as indicated above

ITA 3457/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Aug 2025AY 2017-18

Bench: Shri Saktijit Dey, Vp & Shri Girish Agrawal, Am Accenture Solutions Private Limited Pr. Cit, 501, 5Th Floor, Plat 3, Godrej & Boycee Compound, Vikhroli (W), Vikhroli S.O., Vs. Aayakar Bhavan, M. K. Road, Mumbai-400 079 Mumbai-400 020 Pan/Gir No. (Appellant) : (Respondent) Appellant By : Shri Nishant Thakkar Respondent By : Shri Satya Pal Kumar Date Of Hearing : 18.08.2025 Date Of Pronouncement : 28.08.2025 O R D E R Per Saktijit Dey, Vp: The Captioned Appeal Has Been Filed By The Assessee, Assailing The Order Dated 20.03.2025, Passed U/S. 263 Of Income Tax Act, 1961 (‘The Act’ For Short) By Learned Principal Commissioner Of Income Tax, Mumbai-6 (‘Ld. Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2017-18. 2. We Have Heard The Parties & Perused The Materials Available On Record. The Short Issue Arising For Consideration Is Whether The Final Assessment Order Passed U/S. 144C(13) Of The Act, Can Be Subjected To Revisionary Jurisdiction U/S. 263 Of The Act. For Deciding This Issue, Few Necessary Facts Are Required To Be Considered. The Assessee Is A Resident Corporate Entity Engaged In The Business Of Providing Information Technology (It)/Information Technology Enabled Service (Ites) To Its Group Companies As Well As Consulting Services To Its Clients. For The Assessment Year Under Dispute, The Assessee Filed

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Satya Pal Kumar

Section 143(3)Section 144C(13)Section 263Section 80G

determining the total income at Rs.32,92,97,81,572/-. 3. Against the draft assessment order, the assessee raised objections before ld. Dispute Resolution Panel ('ld. DRP' for short). 4. After considering the submissions of the assessee, ld. DRP disposed of the objections vide directions dated 07.06.2022. In terms with ... when the original assessment order has been passed u/s. 143(3) r.w.s. 144C(13), on the basis of the directions of the Dispute Resolution Panel(DRP). 15. We may gainfully refer to the provision of section 263 in this regard. "263. (1) The Principal Commissioner or Commissioner may call

Garware Fulflex India Pvt Ltd, Mumbai vs. DCIT, Circle 1(1)(1), Mumbai

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

ITA 6751/MUM/2024[2021-22]Status: DisposedITAT Mumbai28 Aug 2025AY 2021-22

Bench: Smt. Beena Pillai () & Shri Om Prakash Kant ()

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

Mumbai (hereinafter shall be referred as ‘Assessing Officer'] for assessment year 2021- 22, pursuant to the direction dated 13.09.2024 of the Ld. Dispute Resolution Panel (DRP). The grounds raised by the assessee in its appeal are reproduced as under: On the facts and in the circumstances of the case ... brevity). On this basis, the Ld. TPO determined the arm's length interest on trade receivables at ₹60,00,261/-. 5.3 The learned Dispute Resolution Panel (“Ld. DRP”) upheld the action of the Ld. TPO in treating the interest on outstanding receivables as a separate international transaction within the meaning

Vishno Motwani, Ajmer vs. Circle(Inttax), Jaipur

Appeal is hereby allowed and the impugned order dated 25

ITA 455/JPR/2024[2015-16]Status: DisposedITAT Jaipur27 Aug 2025AY 2015-16

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Satish Shivnai, C.AFor Respondent: Mrs. Anita Rinesh, JCIT-DR

Section 142(1)Section 144Section 144C(1)Section 148Section 156Section 195Section 271(1)(b)Section 271(1)(c)Section 69

144C of the Income Tax Act (i) The Assessing Officer is directed to complete the assessment as per the above directions of the Dispute Resolution Panel. (ii) The Assessing Officer shall place a copy of these directions as annexure to the final order, to be read as a part ... order. (iii) While passing the final order, the Assessing Officer shall incorporate the reasons given by the Dispute Resolution Panel in respect of various objections, at appropriate places.” 7. After passing of the order dated 08.12.2023, when the matter came up before the Assessing Officer once again, department claims that

ACIT., Circle-1, Nellor vs. Zuari Cement Limited, Kadapa

In the result, the appeal of the Revenue is dismissed

ITA 927/HYD/2025[2010-11]Status: DisposedITAT Hyderabad26 Aug 2025AY 2010-11

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Nitin Narang, C.AFor Respondent: Dr. Narendra Kumar Naik

Section 143(3)Section 144CSection 144C(1)Section 144C(13)Section 254

determining the total income at Rs.252,54,44,320/-, in pursuance of the ITA No.927/Hyd/2025 4 directions of the Learned Dispute Resolution Panel ( “Ld.DRP”). Against the final assessment order of the Ld. AO, the assessee preferred an appeal before the Tribunal. Vide order dated 05.08.2016, this Tribunal set aside

Panda Srinivas, Hyderabad vs. ADIT (Int Taxn)-2, Hyderabad

ITA 682/HYD/2025[2018-19]Status: DisposedITAT Hyderabad26 Aug 2025AY 2018-19

Bench: Us:

Section 143(2)Section 144C(1)Section 144C(5)Section 147Section 148Section 148ASection 54F

aggrieved by the draft assessment order u/s 144C(1) of the Act, dated 26.03.2024 filed objections vide petition in “Form No.35A” before the Dispute Resolution Panel–1, Bengaluru (DRP). However, the DRP rejected the objections filed by the assessee vide its directions u/s 144C(5) of the Act, dated ... pertinent to mention here that appeal against any order passed after incorporation of the directions of Ld. Dispute Resolution Panel lies with the Honourbale Appellate Tribunal. The relevant provisions of sub section 253(1)(d) is reproduced as under: "Section 253(1)(d) in The Income

Natwest Markets Plc - India Branch, Kolkata vs. CIT (It & Tp), Cir- 1(2), Kolkata

In the result the appeal of the assessee is allowed

ITA 997/KOL/2024[2018-2019]Status: DisposedITAT Kolkata26 Aug 2025AY 2018-2019

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Commissioner Of Income Tax Natwest Markets Plc-India (International Taxation & Branch Transfer Pricing) 907, Regus, 9Th Floor, Ps Aaykar Bhavan Poorva, Vs. Arcadia, 4A, Abanindra Nath 2Nd Floor, 110, Shanti Pally, Thakur Sarani, Kolkata-700016 Kolkata-700107, West Bengal (Appellant) (Respondent) Pan No. Aacct8020E Assessee By : Shri Percy Pardiwala, Ar Revenue By : Shri Sandeep Lakra, Dr Date Of Hearing: 31.07.2025 Date Of Pronouncement: 26.08.2025

For Appellant: Shri Percy Pardiwala, ARFor Respondent: Shri Sandeep Lakra, DR

Section 142(1)Section 143(2)Section 143(3)Section 263

therefore respectfully following the above decision of the coordinate bench in assessee’s own case set aside the order of ld. Dispute Resolution Panel/ AO and direct the ld. AO to delete the said addition.” 3.4. Thus the facts before us are materially same as decided by the co-ordinate

M/S. Philips India Ltd., Kolkata vs. DCIT, Circle - 11(1), Kolkata

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

ITA 2610/KOL/2024[2021-2022]Status: DisposedITAT Kolkata26 Aug 2025AY 2021-2022

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm M/S Philips India Limited Rajarhat 4A, 5Th Floor, Ecospace The Dcit Business Park, Premises A4 Ii, Circle 11(1), Aayakar Bhavan, New Town, Chakpachuria, P-7, Chowringhee Square, Vs. Kolkata-700156 Kolkata-700069, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aabcp9487A Assessee By : Shri Ketan Ved, Ar Revenue By : Shri Praveen Kishore, Cit Dr Date Of Hearing: 23.07.2025 Date Of Pronouncement: 26.08.2025

For Appellant: Shri Ketan Ved, ARFor Respondent: Shri Praveen Kishore, CIT DR

Rajesh Kumar, AM: This is an appeal preferred by the assessee against the order of the AP passed after directions by ld. Dispute Resolution Panel (hereinafter referred to as the “Ld. DRP”] dated 13.09.2024 for the AY 2021-22. 2. The issue raised in ground no.1 is general in nature ... case of the Wipro GE Healthcare (P.) Ltd. vs. ACIT (supra). Similarly, we note that the second comparable taken by the AO post Dispute Resolution Panel order i.e. Sasken Technologies Limited is also not comparable to the assessee for the reason that the same is not functionally comparable

M/S. International Specialty Products (India) Private Limited, Hyderabad vs. Circle 15(1)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 3255/MUM/2025[2012-13]Status: DisposedITAT Mumbai26 Aug 2025AY 2012-13

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2012-13

For Appellant: Shri P.V.S.S. Prasad, CAFor Respondent: Shri Virabhadra S. Mahajan, Sr. DR

Section 271Section 271(1)(c)Section 92C

Officer after considering the Transfer Pricing Order, passed the Draft Assessment Order. Assessee filed objections against the draft assessment order before the Ld. Dispute Resolution Panel 4 International Specialty Products (India) Pvt. Ltd. AY 2012-13 (DRP). Ld. DRP reduced the proposed adjustment to Rs.143.59 Lakhs, details tabulated below

J P Morgan Services India Pvt Ltd, Mumbai vs. DCIT Circle 2(2)(1), Mumbai

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

ITA 6563/MUM/2024[2021-22]Status: DisposedITAT Mumbai26 Aug 2025AY 2021-22

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalj P Morgan Services India Private Limited Tower A Blk 9, Tower B Blk 10, Tower C Blk 11, Nirlon Knowledge Park, Western Express Highway, Goregaon East, Mumbai Suburban, ............... Appellant 400063. Pan : Aabcd0503B V/S Deputy Commissioner Of Income-Tax, Circle 2(2)(1), ……………… Respondent Aayakar Bhawan, Maharshi Karve Road, New Marine Lines, Churchgate, Mumbai-400020. Assessee By : Shri Fenil Bhatt Revenue By : Ms. Neena Jeph, Cit.Dr

For Appellant: Shri Fenil BhattFor Respondent: Ms. Neena Jeph, CIT.DR

Section 143(3)Section 144BSection 144CSection 144C(12)Section 144C(13)Section 144C(5)Section 153Section 92D

r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (“the Act”) pursuant to the directions dated 25.09.2024 issued by the Dispute Resolution Panel-1, Mumbai (“learned DRP”) under section 144C(5) of the Act, for the assessment year 2021-22. 2. In this appeal, the assessee has raised ... Income Tax Department ('Ld. AO') and directions issued under section 144C(5) of the Act dated 25 September 2024 by the Hon'ble Dispute Resolution Panel ('Hon'ble DRP'), to the extent prejudicial to the Appellant, is erroneous and bad in law. 2. On the facts and in the circumstances

Aapc India Hotel Management Private Limited, Delhi vs. Assessment Unit, Income Tax Department, Delhi

ITA 3588/DEL/2024[2020-21]Status: DisposedITAT Delhi26 Aug 2025AY 2020-21

Bench: Shri Sudhir Pareek & Shri Avdhesh Kumar Mishra

Section 143(3)Section 144BSection 144CSection 153Section 156Section 23Section 234BSection 234C

facts of the case and in law, the Learned Transfer Pricing Officer ('Ld. TPO) and Ld. Dispute Resolution Panel ('DRP') erred in proposing an adjustment on account of arm's length price for the transaction of availing technical consultancy services. In doing so, the Ld. TPO/L4 DRP erred

Keller Asiapacific Limited, Singapore vs. The Assistant Commissioner of Income Tax, Circle International Taxation

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

ITA 3540/DEL/2023[2021-22]Status: DisposedITAT Delhi26 Aug 2025AY 2021-22

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.3540/दिल्ली/2023 (नि.व. 2021-22)

For Appellant: Shri Ashik Shah, CAFor Respondent: Ms. Anjula Jain, CIT-DR

Section 143(3)

year for adjudication of the issue on merits. 2.2 Aggrieved by the draft Assessment Order dated 28.12.2022, the assessee filed objections before the Dispute Resolution Panel (DRP). The DRP without appreciating the facts upheld findings of the AO in draft Assessment Order. The Id. AR of assessee contended that assessee

Metso Oyj, Finland vs. Assistant Commissioner of Income Tax, (International Taxation), Circle-1(2), Kolkata

In the result, the appeal filed by the assessee is dismissed and the order of the Ld

ITA 616/KOL/2025[2022-23]Status: DisposedITAT Kolkata25 Aug 2025AY 2022-23

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 143(3)Section 144C(13)Section 144C(5)Section 234BSection 270ASection 56Section 9

hereinafter referred to as ‘the Act’) for AY 2022-23 dated 23.01.2025, which has been passed against the order of the Dispute Resolution Panel (the ‘Ld. DRP/Ld. Panel’) u/s 144C(5) of the Act, dated 30.12.2024. 2. The assessee is in appeal before the Tribunal raising the following grounds ... written submission made may be considered, which have been considered. The Ld. DR relied upon the directions of the Dispute Resolution Panel and the order of the Tribunal in the assessee’s own case for AY 2018-19 & AY 2020-21. Since this issue has been decided against the assessee

Kaliyaperumal Padmanaban, Cuddalore vs. ITO, Ward-2, Cuddalore

In the result, appeal filed by the assessee is allowed

ITA 1176/CHNY/2025[2012-13]Status: DisposedITAT Chennai25 Aug 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.N. Arjun Raj, AdvocateFor Respondent: Ms. Anitha, Addl. CIT

Section 144

Appellate Tribunal [hereinafter referred to as 'ITAT']. 3. ITAT by impugned order allowed the appeal holding that the direction issued by the Dispute Resolution Panel [hereinafter referred to as 'DRP'] under Section 144C (5) of the Act did not contain a Document Identification Number [hereinafter referred

Rolta India Ltd. Through Dr. Mamta Binani, Rp., Mumbai vs. Dy.Commissioner of Income Tax Central Circle -1(1), Mumbai

In the result, appeal of the assessee in ITA No

ITA 3563/MUM/2024[2020-21]Status: DisposedITAT Mumbai25 Aug 2025AY 2020-21

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.3563/Mum/2024 "नधा"रण वष" / Assessment Year :2020-21 Rolta India Ltd. Through Dr. Mamta Binani, Rp. Rolta Tower-A, Rolta Technology Park, 22Nd Street, Midc, Marol Andheri (East), Mumbai-400 093 Pan: Aaacr2711G ........अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax, Central Circle-1(1), Mumbai ……""यथ" / Respondent आयकर अपील सं. / Ita No.2737/Mum/2023 "नधा"रण वष" / Assessment Year :2018-19 Rolta India Ltd. Through Dr. Mamta Binani, Irp. Rolta Tower-A, Rolta Technology Park, 22Nd Street, Midc, Marol Andheri (East), Mumbai-400 093 Pan: Aaacr2711G ........अपीलाथ" / Appellant M/S. Rolta India Ltd. बनाम / V/S. The Deputy Commissioner Of Income Tax, Central Circle-1(1), Mumbai ……""यथ" / Respondent

For Appellant: Shri Shekhar Gupta, CAFor Respondent: Shri Pankaj Kumar, CIT-DR

Section 143(3)Section 144C(13)Section 144C(5)Section 37(1)Section 92C

आदेश / ORDER PER ARUN KHODPIA, AM: The captioned appeals filed by the assessee company are directed against the orders passed by the Dispute Resolution Panel (for short ‘DRP’) passed u/s.144C(5) of the Income-tax Act, 1961 (in short, ‘the Act’) dated 17.05.2024 & 28.06.2022 which in turn arises from ... lead matter for adjudication, wherein the assessee has raised following grounds of appeal: “1. The learned Assessing Officer pursuant to the directions of Dispute Resolution Panel has confirmed the order of the Transfer Pricing Officer making an addition of Rs.2,98,53,254/- on account of interest on interest free

Rolta India Ltd, Mumbai vs. DCIT, Central Circle-1(1), Mumbai

In the result, appeal of the assessee in ITA No

ITA 2737/MUM/2023[2018-19]Status: DisposedITAT Mumbai25 Aug 2025AY 2018-19

For Appellant: Shri Shekhar Gupta, CAFor Respondent: Shri Pankaj Kumar, CIT-DR

Section 143(3)Section 144C(13)Section 144C(5)Section 37(1)Section 92C

Goldman Sachs (India) Finance Private Limited, Mumbai vs. Assessment Unit, Income-Tax Department, New Delhi

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

ITA 6766/MUM/2024[AY 2021-22]Status: DisposedITAT Mumbai22 Aug 2025

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Madhur AgrawalFor Respondent: Ms. Neena Jeph, CIT-DR

Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(1)Section 144C(5)Section 253Section 32Section 37(1)

r.w.s.144C(13) r.w.s. 144B of the Income Tax Act, 1961 (“the Act”) pursuant to the directions dated 16.09.2024 issued by the Dispute Resolution Panel-3, Mumbai (“learned DRP") under section 144C(5) of the Act, for the assessment year 2021-22. 2. The brief facts of the case are that

Red Hat India Private Limited, Mumbai vs. Assistant Commissioner of Income Tax/ITO/ Circle 15(3)(1), Mumbai

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

ITA 2442/MUM/2022[2018-19]Status: DisposedITAT Mumbai22 Aug 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Arun Khodpiaassessment Year : 2018-19 Red Hat India Private Limited, Asst. Commissioner Of A-201, Supreme Business Park, Income Tax/Income Tax Officer, Supreme City, Vs. Circle-15(3)(1), Hiranandani Gardens, Mumbai. Powai, Mumbai-400076. Pan : Aabcr7097N (Appellant) (Respondent) For Assessee : Shri Ajit Jain, For Revenue : Shri Pankaj Kumar, Cit-Dr Date Of Hearing : 13-08-2025 Date Of Pronouncement : 22-08-2025 O R D E R Per Amit Shukla, J.M : The Aforesaid Appeal Has Been Filed By The Assessee Against The Final Assessment Order Dated 27/07/2022 Passed By The Acit, Circle 15(3)(1) Mumbai, U/S 144C(13) For The A.Y. 2018-19, In Pursuance To The Directions Issued By The Dispute Resolution Panel-2, Mumbai-2, Dated 15/06/2022 U/S 144C(5).

For Appellant: Shri Ajit JainFor Respondent: Shri Pankaj Kumar, CIT-DR

Section 144C(13)Section 144C(5)

ACIT, Circle 15(3)(1) Mumbai, u/s 144C(13) for the A.Y. 2018-19, in pursuance to the directions issued by the Dispute Resolution Panel-2, Mumbai-2, dated 15/06/2022 u/s 144C(5). 2. The brief facts apropos the case are that, the assessee company is a part

Mondelez India Foods Pvt. Ltd. (Formerly Known As Cadbury India Ltd.), Mumbai vs. ACIT, Range 5 (1)(2), Mumbai

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

ITA 7269/MUM/2019[2015-16]Status: DisposedITAT Mumbai22 Aug 2025AY 2015-16

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.7269/Mum/2019 निर्धारण वर्ष / Assessment Year :2015-16 M/S Mondelez India Foods Private Limited (Formerly Known As Cadbury India Limited), Mondelez House, Unit No.2001, 20Th Floor Tower-3 (Wing C) India Bulls Finance Centre), Parel, Mumbai-400 013 Pan : Aaac0460H ........अपीलार्थी / Appellant बनाम / V/S. The Assistant Commissioner Of Income-Tax, Range-5(1)(2), Mumbai, Aayakar Bhavan, M.K. Road Mumbai-400 020 ......प्रत्यर्थी / Respondent Assessee By : Shri J.D. Mistri, Sr. Advocate Shri Hiten Chande Revenue By : Shri Pankaj Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing :18.08.2025 घोषणा की तारीख / Date Of Pronouncement : 22.08.2025

For Appellant: Shri J.D. Mistri, Sr. AdvocateFor Respondent: Shri Pankaj Kumar, CIT-DR

Section 115JSection 143(3)Section 144C(1)Section 144C(5)Section 14ASection 234C

ARUN KHODPIA, AM: आदेश / ORDER The present appeal filed by the assessee company isdirected against the order passed by the Dispute Resolution Panel-3 (WZ) (for short ‘DRP') passed u/s.144C(5) of the Income-tax Act, 1961 (in short, ‘the Act') dated 23.09.2019 which in turn arises from the assessment

Bain and Company, Usa vs. DCIT, Gurgoan

In the result, appeal of assessee in ITA Nos

ITA 3056/DEL/2023[2021-22]Status: DisposedITAT Delhi22 Aug 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Ms. Ekta Jain, CIT- DR

Section 143(3)

against the returned income of Rs.27,57,87,110/- declared by the Appellant. GROUNDS PERTAINING TO MANAGEMENT CONSULTING SERVICES 2.That the Ld. AO/ Dispute Resolution Panel ('DRP') erred on facts and in law in holding that the fee for management consulting services amounting to Rs.49,79,77,135/-received

Bain & Company, Inc., Usa vs. DCIT Intl. Taxation Circle, New Delhi

In the result, appeal of assessee in ITA Nos

ITA 1677/DEL/2023[2020-21]Status: DisposedITAT Delhi22 Aug 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Ms. Ekta Jain, CIT- DR

Section 143(3)