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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

Precision Camshafts Ltd., Solapur vs. Assessment Unit, Income Tax Department (NFAC), Solapur

In the result, appeal of the assessee is allowed

ITA 1962/PUN/2024[2020-21]Status: DisposedITAT Pune10 Jul 2025AY 2020-21

Bench: Ms. Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.1962/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Precision Camshafts Ltd., V Assessment Unit, Income Tax E-102/103, Akkalkot Road, S Department (National Midc, Solapur – 413006. Faceless Assessment Center), Maharashtra. Jurisdiction Details : Pne- C(1), Range 63, Circle-1, Solapur. Pan: Aabcp1086B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 17/06/2025 Date Of Pronouncement 10/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Assessment Unit, Income Tax Department Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 25.07.2024, Emanating From Order Of Dispute Resolution Panel U/S.144C(5) Of The Act For A.Y.2020-21

Section 143(3)Section 144BSection 144C(5)Section 92(3)Section 928Section 92C

r.w.s 144C(3) read with section 144B of the Income Tax Act, 1961 for A.Y.2020-21 dated 25.07.2024, emanating from order of Dispute Resolution Panel u/s.144C(5) of the Act for A.Y.2020-21, ITA No.1962/PUN/2024 [A] dated 10.06.2024. The Assessee has raised the following grounds of appeal : “A. Transfer Pricing Issues ... Accordingly, proposed an addition of Rs.30.98 lakhs. Aggrieved by the order of the Transfer Pricing Officer, Assessee filed appeal before the Dispute Resolution Panel(DRP). The DRP upheld the order of TPO regarding Corporate Guarantee Commission. Nowhere, either the DRP or TPO has mentioned how they have arrived

Sivakarthick Raman, Madurai vs. The Assistant Commissioner of Income Tax, International Taxation, Circle Madurai

In the result, the appeal of the assessee is allowed in terms of our above order

ITA 281/CHNY/2025[2022-23]Status: DisposedITAT Chennai07 Jul 2025AY 2022-23

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:281/Chny/2025 िनधा"रण वष" / Assessment Year: 2022-23 Sivakarthick Raman, The Assistant Commissioner Of 5/200, 2Nd Street, Alagupillai Nagar, Vs. Income Tax, T.Pudukudi, International Taxation Circle, Achampathu, Madurai. Madurai – 625 019. [Pan: Ajnpr-3214-R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Ms. Preeti Goel, Advocate ""थ" की ओर से/Respondent By : Ms. Anitha, Addl. C.I.T. सुनवाई की तारीख/Date Of Hearing : 21.04.2025 घोषणा की तारीख/Date Of Pronouncement : 07.07.2025 आदेश /O R D E R Per S. R. Raghunatha, Am:

For Appellant: Ms. Preeti Goel, AdvocateFor Respondent: Ms. Anitha, Addl. C.I.T
Section 143(3)Section 144C(13)Section 15Section 15(1)(a)Section 234BSection 234DSection 5(2)Section 5(2)(a)Section 9(1)(ii)Section 90

Rs.52,22,590/-. 10. However, pursuant to scrutiny proceedings, the AO has in his Final :-6-: ITA. No.:281/Chny/2025 assessment order and the Dispute Resolution Panel (‘DRP’) in the directions issued, disallowed the exemption claimed and hence the assessee preferred present appeal before us. 11. The ld.AR for the assessee ... submitted that the detailed facts are summarised in Annexure to Form 35A submitted before the Dispute Resolution Panel at Pages 271 to 303 of the Paper book filed. Grounds 1, 2 and 3 12. The ld.AR submitted that the AO has in pursuance of the Directions of the DRP erred

Ashok Appaji Patil, Belgaum vs. Intl. Taxation Ward, Panaji

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

ITA 49/PAN/2025[2016-17]Status: DisposedITAT Panaji03 Jul 2025AY 2016-17

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A.No.49/Pan/2025 (A.Y.2016-17) Ashok Appaji Patil, Vs. I T O, 3338/1A,Sankalp International Taxation, Building, 3 Floor, Gondhalli Galli, Reac, Belagavi-590001, Panaji-403001, Karnataka. Goa. Pan/Gir No:Aqopp2917M Appellant .. Respondent Appellant By : Letter Dt 1-07-2025. Respondent By : Smt.Rijula Uniyal.Sr.Dr Date Of Hearing 02.07.2025 Date Of Pronouncement 03.07.2025 आदेश / O R D E R Per Pavan Kumar Gadale, Jm: The Assessee Has Filed The Appeal Against The Order Of The Assessing Officer Passed U/S 144 R.W.S 144C(13) Of The Income Tax Act, 1961 Passed In Pursuance To The Directions Of The Dispute Resolution Panel (Drp) U/S 144C(5) Of The Act. The Assessee Has Raised Grounds Of Appeal Challenging The Action Of Lower Authorities Drp/Ao Partly Sustaining The Addition Without Providing

For Appellant: Letter dt 1-07-2025For Respondent: Smt.Rijula Uniyal.Sr.DR
Section 144Section 144C(1)Section 144C(5)

Assessing Officer passed u/s 144 r.w.s 144C(13) of the Income Tax Act, 1961 passed in pursuance to the directions of the Dispute Resolution Panel (DRP) u/s 144C(5) of the Act. The assessee has raised grounds of appeal challenging the action of lower authorities DRP/AO partly sustaining the addition ... 144C(1) of the Act. 3. Aggrieved with the draft assessment order, the assessee has filed the objections in Formno-35A with the Dispute Resolution Panel (DRP). The DRP has dealt on the objections, submissions and remand report and issued directions to the A.O for deleting the addition u/sec69