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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

Stryker India Private Limited, New Delhi vs. ACIT, Circle-22(2), New Delhi

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

ITA 2449/DEL/2022[2018-19]Status: DisposedITAT Delhi22 Aug 2025AY 2018-19

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalstryker India Private Limited Assistant Commissioner C-5, Sda Commercial Complex, Of Income Tax, New Delhi-110016. Vs. Circle-22(2), New Delhi. Pan-Aaecs2513F (Appellant) (Respondent)

Section 92C

Assistant Commissioner of Income Tax, Circle 22(2), New Delhi ("Ld. AO") following the directions of the Hon'ble Dispute Resolution Panel ("DRP"), erred in enhancing the income of the Appellant by INR 2,35,91,515/-, on account of Transfer Pricing ("TP") adjustment u/s 92CA(3) of the Income

M/S Kohinoor Foods Ltd., Delhi vs. ACIT, New Delhi

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

ITA 1549/DEL/2016[2011-12]Status: DisposedITAT Delhi22 Aug 2025AY 2011-12

Bench: SHRI PRAKASH CHAND YADAV (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

raised or not by the eligible assessee. Section 144 C(8) and the Explanation appended thereto reads as under:— "144C (8) The Dispute Resolution Panel may confirm, reduce or enhance the variations proposed in the draft order so, however, that it shall not set aside any proposed variation or issue ... further enquiry and passing of the assessment order. Explanation. — For the removal of doubts, it is hereby declared that the power of the Dispute Resolution Panel to enhance the variation shall include and shall be deemed always to have included Kohinoor Foods Ltd. vs. ACIT the power to consider

M/S Kohinoor Foods Ltd, New Delhi vs. Deputy Commissioner of Income-Tax, New Delhi

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

ITA 1900/DEL/2015[2010-11]Status: DisposedITAT Delhi22 Aug 2025AY 2010-11

Bench: SHRI PRAKASH CHAND YADAV (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

raised or not by the eligible assessee. Section 144 C(8) and the Explanation appended thereto reads as under:— "144C (8) The Dispute Resolution Panel may confirm, reduce or enhance the variations proposed in the draft order so, however, that it shall not set aside any proposed variation or issue ... further enquiry and passing of the assessment order. Explanation. — For the removal of doubts, it is hereby declared that the power of the Dispute Resolution Panel to enhance the variation shall include and shall be deemed always to have included Kohinoor Foods Ltd. vs. ACIT the power to consider

Narayanan, Chromepet vs. Income Tax Officer, Chennai

In the result, the appeal filed by the assessee is dismissed

ITA 695/CHNY/2025[2018-2019]Status: DisposedITAT Chennai20 Aug 2025AY 2018-2019

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.695/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Narayanan, Vs. The Income Tax Officer, F-1, 37/60, Guru Balaji Apts, International Taxation Ward 2(1), First Main Road, New Colony, Chennai. Chromepet, Chennai 600 044. [Pan:Ackpn6481A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 24.07.2025 घोषणा की तारीख /Date Of Pronouncement : 20.08.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Final Assessment Order Dated 06.01.2025 Passed By The Income Tax Officer, International Taxation Ward 2(1), Chennai Under Section 147 R.W.S. 144C(13) Of The Income Tax Act, 1961 [“Act” In Short] For The Assessment Year 2018-19. 2. When The Appeal Was Taken Up For Hearing On 24.07.2025, We Find No Representation On Behalf Of The Assessee. However, We Find Paper

For Appellant: NoneFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 142(1)Section 143(2)Section 144C(1)Section 147Section 148Section 69

Assessing Officer proposed draft assessment order dated 18.03.2024 under section 144C(1) of the Act. 4. The assessee filed objections before the Dispute Resolution Panel on 17.04.2024 with other details. Since the assessee filed details and documents before DRP which were not filed before the AO, the DRP called ... during course of assessment proceedings and relevant para 6 of the assessment order is reproduced hereinbelow: 6. The assessee filed objections before the Dispute Resolution Panel on 17.04.2024 with other details. Since the assessee filed details and documents before DRP which were not filed before the AO, the DRP called

Khvatec India Private Limited, Gautam Buddha Nagar vs. Assessing Officer, Noida Up

In the result, appeal of the assessee is dismissed as withdrawn, as indicated above

ITA 5650/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Aug 2025AY 2021-22

Bench: Shri Sudhir Pareek & Shri Manish Agarwal

For Appellant: Shri Prem Lamba, CAFor Respondent: Shri Dharm Veer Singh, CIT(DR)
Section 143(3)Section 144C

144B of the Income-tax Act, 1961 (“the Act”), pursuant to ITA No.-5650/Del/2024 KHVATEC India Pvt. Ltd. the directions of the Dispute Resolution Panel Dated 30.08.2024 for the Assessment Year 2021-22. At the time of hearing before us, Ld. AR for Assessee informed 2. that the assessee

Btl Industries Ltd, New Delhi vs. DCIT, Central Circle-II, Faridabad

In the result, appeals of the assessee are partly allowed

ITA 7430/DEL/2019[2008-09]Status: DisposedITAT Delhi20 Aug 2025AY 2008-09

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahman

Section 143(2)Section 14ASection 153Section 153ASection 153A(1)(b)Section 234B

made. Accordingly, a draft assessment order was framed by the AO on 31.03.2014. 8. Qua this, respondent/assessee preferred its objections with the Dispute Resolution Panel (DRP). The DRP dismissed the objections on 21.10.2014. It is pursuant to the dismissal of the respondent/assessee's objection, that the AO framed the assessment

Btl Industries Ltd, New Delhi vs. DCIT, Central Circle-II, Faridabad

ITA 3620/DEL/2018[2013-14]Status: DisposedITAT Delhi20 Aug 2025AY 2013-14

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahman

Section 143(2)Section 14ASection 153Section 153ASection 153A(1)(b)Section 234B

ITA Nos.7430/Del/2019 & 3618 to 3620/Del/2018 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “A” NEW DELHI BEFORE SHRI CHALLA NAGENDRA

Btl Industries Ltd, New Delhi vs. DCIT, Central Circle-II, Faridabad

In the result, appeals of the assessee are partly allowed

ITA 3619/DEL/2018[2011-12]Status: DisposedITAT Delhi20 Aug 2025AY 2011-12

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahmanassessment Year: 2008-09 बनाम Btl Industries Ltd., Dcit, (Merged With & Now Known As Vs. Central Circle-Ii, M/S Btl Holding Co. Ltd.), Faridabad, C/O Srs Mall, Third Floor, Haryana. Sector-12, Faridabad, Haryana. Pan No.Aaccb0573C अपीलाथ" Appellant ""यथ"/Respondent &

Section 143(2)Section 14ASection 153Section 153ASection 153A(1)(b)Section 234B

made. Accordingly, a draft assessment order was framed by the AO on 31.03.2014. 8. Qua this, respondent/assessee preferred its objections with the Dispute Resolution Panel (DRP). The DRP dismissed the objections on 21.10.2014. It is pursuant to the dismissal of the respondent/assessee’s objection, that the AO framed the assessment

Btl Industries Ltd, New Delhi vs. DCIT, Central Circle-II, Faridabad

ITA 3618/DEL/2018[2010-11]Status: DisposedITAT Delhi20 Aug 2025AY 2010-11

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahman

Section 143(2)Section 14ASection 153Section 153ASection 153A(1)(b)Section 234B

ITA Nos.7430/Del/2019 & 3618 to 3620/Del/2018 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “A” NEW DELHI BEFORE SHRI CHALLA NAGENDRA

Indian Metals and Ferro Alloys Ltd, Bhubaneswar vs. DCIT, Circle-1(1), Bhubaneswar

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

ITA 506/CTK/2024[2021-22]Status: DisposedITAT Cuttack19 Aug 2025AY 2021-22

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 143(1)Section 143(2)Section 143(3)Section 144C(5)Section 234BSection 234CSection 270ASection 92CSection 92D

order u/s 143(3) r.w.s. 144C(1) of the Act was passed. Against the draft assessment order, the assessee filed objections before the Dispute Resolution Panel which passed an order u/s 144C(5) of the Act upholding the additions proposed by the Ld. TPO. The directions of the Dispute Resolution ... respect of specified domestic transactions of the assessee. 3.0 The assessee company had filed an objection before the Dispute Resolution Panel (DRP). New Delhi against the draft order. The Ld. DRP after hearing to the assessee's contentions passed its directions on 30.09.2024, directing the AO/TPO to take recommended action

Rubicon Research Limited (Formerly Known As Rubicon Research Private Limited), Thane, Maharashtra vs. Deputy Commissioner of Income Tax - Circle 15(3)(1), Mumbai

In the result, assessee’s appeal is allowed for statistical purposes

ITA 6647/MUM/2024[2021-22]Status: DisposedITAT Mumbai18 Aug 2025AY 2021-22

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No.6647/Mum/2024 (निर्धारण वर्ा/Assessment Year: 2021-22) Rubicon Research V/S. Deputy Commissioner Of Limited (Formerly बिधम Income Tax- Circle Known As Rubicon 15(3)(1), Mumbai Research Private Aaykar Bhavan, Maharshi Limited) Karve Road, New Marine Medone House, B-75, Lines, Churchgate, Mumbai Road No. 33, Wagle 400020 Estate, Thane 400604. Assessment Unit, National Faceless Assessment Centre Income Tax Department, Ministry Of Finance Delhi स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcr1422M Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी निर्ााररती की ओर से /Assessee By: Shri. Darpan Kirpalani रधजस्व की ओर से /Revenue By: Shri. Asif Karmali (Sr Dr)

For Appellant: Shri. Darpan KirpalaniFor Respondent: Shri. Asif Karmali (SR DR)
Section 143(3)Section 153Section 234BSection 37Section 92CSection 92C(3)Section 92D

Already Examined the Evidences Twice 1. During the TP assessment proceedings and again in the remand proceedings before the Dispute Resolution Panel ("DRP"), the Assessee has filed comprehensive evidences including: • Detailed case studies evidencing need of the services by the Assessee and benefit received thereon, • Email communications, presentations, meetings, • Inter

Ravi Kumar, New Delhi vs. DCIT, Circle Int. Tax 2(1)(2), New Delhi

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

ITA 1783/DEL/2024[2017-18]Status: DisposedITAT Delhi18 Aug 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 144CSection 147Section 148Section 148ASection 68Section 8

International Tax, Circle -2(1)(2), New Delhi. 2. The assessee has raised following grounds in this appeal: “1. That the Hon'ble Dispute Resolution Panel has erred in law in not issuing specific directions to the AO with respect to the addition made in the draft assessment order ... express provisions of sub-section 8 of section 144C of the Income Tax Act, 1961. 1 Ravi Kumar 2. That the Hon'ble Dispute Resolution Panel has erred in law in holding that it had no power to decide the issue of validity/maintainability of the issue of notice

Cisco Systems (India) Private Limited, Bnagalore vs. DCIT- Circle 2(2)(1), Bangalore

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

ITA 1891/BANG/2024[AY 2020-21]Status: DisposedITAT Bangalore14 Aug 2025

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadavit(Tp)A No.1891/Bang/2024 Assessment Year : 2020-21 M/S. Cisco Systems (India) Pvt. Ltd., Vs. The Assistant Commissioner Sez Unit Kadubeesanahalli Village, Of Income Tax, Bellandur S.O. Kadabeesanahalli, Circle – 2(2)(1), Bangalore – 560 103. Bangalore. Pan: Aabcc 0258 Q Appellant Respondent Appellant By : Shri. Nageshwar Rao, Advocate Respondent By : Dr. Divya K. J, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 11.08.2025 Date Of Pronouncement : 14.08.2025

For Appellant: Shri. Nageshwar Rao, AdvocateFor Respondent: Dr. Divya K. J, CIT(DR)(ITAT), Bangalore
Section 143(3)Section 234A

this assessment, the transfer pricing adjustment was retained of Rs.53,40,15,927/- after the direction of the learned Dispute Resolution Panel (learned DRP), Bangalore, dated 18.06.2024. 2. Assessee is aggrieved and has preferred this appeal raising grounds against transfer pricing matters. As per ground Nos.1-4, assessee contends that there

Juhi Bhandari, Jaipur vs. DCIT Circle (Intl Tax), Jaipur

In the result, both appeals of the assessee are allowed

ITA 234/JPR/2025[2015-16]Status: DisposedITAT Jaipur13 Aug 2025AY 2015-16
For Appellant: Shri Siddharth Ranka, AdvFor Respondent: Smt. Runi Pal, CIT (through VC)
Section 144C(5)Section 153CSection 69

short Act] for the assessment year 2015-2016. That order of assessment was passed after considering the direction of Dispute Resolution Panel [in short "DRP'] passed under Section 144C(5) of the Act dated 19.12.2024. 2. As the issues in both appeals are similar, related, and were heard together ... 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.1,31,79,660 to the income of the assessee under Section

Sharad Kumar Bhandari, Jaipur vs. DCIT Circle (Intl Tax), Jaipur

ITA 232/JPR/2025[2015-16]Status: DisposedITAT Jaipur13 Aug 2025AY 2015-16
For Appellant: Shri Siddharth Ranka, AdvFor Respondent: Smt. Runi Pal, CIT (through VC)
Section 144C(5)Section 153CSection 69

short Act] for the assessment year 2015-2016. That order of assessment was passed after considering the direction of Dispute Resolution Panel [in short "DRP"] passed under Section 144C(5) of the Act dated 19.12.2024. 2. As the issues in both appeals are similar, related, and were heard together ... 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.1,31,79,660 to the income of the assessee under Section

Assistant Commissioner of Income Tax, Circle-1, Tiruppur vs. Prabhu Spinning Mills Private Limited, Tiruppur

ITA 435/CHNY/2025[2017-18]Status: DisposedITAT Chennai13 Aug 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:433 & 435/Chny/2025 निर्धारण वर्ष / Assessment Year: 2018-19 & 2017-18 Acit, Circle -1 121, Adarns Plaza, 60, Feet Road, Tiruppur - 641 602. (अपीलार्थी/Appellant) Vs. Prabhu Spining Mills Private Limited, No. 207 – 86, Mangalam Road, Karuvampalayam, Tiruppur – 641 604. Tamil Nadu. [Pan:Aabcp-0750-E] (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. Arv Sreenivasan, Cit प्रत्यर्थी की ओर से/Respondent By : Shri. T. Banusekar, Advocate. सुनवाई की तारीख/Date Of Hearing : 16.07.2025 घोषणा की तारीख/Date Of Pronouncement : 13.08.2025 Per S. R. Raghunatha, Am : आदेश /Order These Two Appeals Filed By The Revenue Are Directed Against Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Chennai-16 (In Short “Id.Cit(A)”) Dated 04.10.2024 For Assessment Years 2017-18 & 2018-19 Respectively. Since Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals By The Revenue Are Being Heard Together & Disposed Of By This Consolidated Order. 2. The Appeal Of The Revenue For The Assessment Year 2017-18 Is Taken As The Lead Appeal For Adjudication Of The Issues Involved. The Only Issue Which Has Been Raised In Appeal By The Revenue Is With Regard To Determination Of Quantum Of Deduction U/S.80-Ia Of The Income Tax Act, 1961 (In Short "The Act"). :-2-:

For Appellant: Shri. ARV Sreenivasan, CITFor Respondent: Shri. T. Banusekar, Advocate
Section 143(3)Section 80Section 92C

Nos.265, 266 & 267 / Chny / 2025 – Chennai ITAT • DCIT v Phillips Carbon Black Ltd. [2025] 175 taxmann.com 352 (Kol Trib.) • Even the Dispute Resolution Panel, Bengaluru in the case of Sulochana Cotton Spinning Mills (P.) Ltd. for the assessment year 2020-21 vide its directions dated 28.06.2024 has taken the same

Assistant Commissioner of Income Tax, Tiruppur vs. Prabhu Spinning Mills Private Limited, Tiruppur

In the result all the grounds raised by the revenue for the A

ITA 433/CHNY/2025[2018-19]Status: DisposedITAT Chennai13 Aug 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:433 & 435/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2018-19 & 2017-18 Acit, Circle -1 Prabhu Spining Mills Private 121, Adarns Plaza, Vs. Limited, 60, Feet Road, No. 207 – 86, Mangalam Road, Tiruppur – 641 602. Karuvampalayam, Tiruppur – 641 604. Tamil Nadu. (अपीलाथी/Appellant) [Pan:Aabcp-0750-E] (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. Arv Sreenivasan, Cit प्रत्यथी की ओर से/Respondent By : Shri. T. Banusekar, Advocate. सुनवाई की तारीख/Date Of Hearing : 16.07.2025 घोर्णा की तारीख/Date Of Pronouncement : 13.08.2025

For Appellant: Shri. ARV Sreenivasan, CITFor Respondent: Shri. T. Banusekar, Advocate
Section 143(3)Section 80Section 92C

Nos.265, 266 & 267 / Chny / 2025 – Chennai ITAT  DCIT v Phillips Carbon Black Ltd. [2025] 175 taxmann.com 352 (Kol Trib.)  Even the Dispute Resolution Panel, Bengaluru in the case of Sulochana Cotton Spinning Mills (P.) Ltd. for the assessment year 2020-21 vide its directions dated 28.06.2024 has taken the same

Tfdac Ireland II Limited, Ireland vs. Deputy Commissioner of Income Tax International Tax Circle 4(1)(2) Mumbai, Mumbai

ITA 1198/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Aug 2025AY 2022-23
Section 143(3)Section 144C(13)Section 144C(5)

Income-tax Act, 1961 (“the Act”) for the Assessment Year 2022–23, in pursuance of directions issued by the Hon'ble Dispute Resolution Panel–2, Mumbai (“the DRP”) under section 144C(5). While the appeals are separate in form, the underlying facts, nature of transactions, and legal controversies are materially

Ortus Aircraft Lease 5( Dublin) Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(2)(2) International Taxation, Mumbai

ITA 1108/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Aug 2025AY 2022-23

Income-tax Act, 1961 (“the Act”) for the Assessment Year 2022–23, in pursuance of directions issued by the Hon‟ble Dispute Resolution Panel–2, Mumbai (“the DRP”) under section 144C(5). While the appeals are separate in form, the underlying facts, nature of transactions, and legal controversies are materially

Sunflower Aircraft Leasing Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 4(2)(2) International Tax, Mumbai

In the result, the appeal of the assessee stands allowed

ITA 1107/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Aug 2025AY 2022-23
Section 143(3)Section 144C(13)Section 144C(5)Section 9(1)(vi)

Assistant Commissioner of Income-tax, Circle-4(2)(2), Mumbai (“the AO”), pursuant to the directions issued by the Dispute Resolution Panel, New Delhi (“the DRP”), under section 144C(5) of the Act for the assessment year 2022-23. 2. The controversy in the present case has its genesis