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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

Kbs Creation Ltd, Mumbai vs. Dy Comm. of Income Tax -Circle 24(1), Mumbai

In the result, the concise ground of appeal of the assessee is allowed

ITA 6477/MUM/2024[2021-22]Status: DisposedITAT Mumbai16 Jun 2025AY 2021-22

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 10ASection 143(3)Section 254(1)Section 80ISection 92C

additions in assessment order dated 25/10/2024 passed under section 143(3) r.w.s. 144C(13) and 144(B), passed in pursuance of direction of Dispute Resolution Panel (DRP) dated 24/09/2024 for Assessment Year (AY) 2021-22.The Assessee has raised following concise grounds of appeal; 1. The learned NeAC officer has erred ... assessment order dated 12.12.2023, passed under section 144C(1) was served on the assessee. The assessee exercised its option for filling objection before Dispute Resolution Panel (DRP). 4. Before the DRP the assessee file detailed written submission. The assessee before DRP submitted that AO has erred in making reference

Employees Retirement System of Texas, Mumbai vs. Dy CIT (Int. Tax)-2(2)(1), Mumbai

The appeals are partly allowed

ITA 2155/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Jun 2025AY 2022-23

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Anish ThackarFor Respondent: Shri Satya Pal Kumar
Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 70Section 70(2)

144B of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’], as per the directions issued by Commissioner of Income Tax [Dispute Resolution Panel (1)], Mumbai-3 [for short ‘DRP’] [on 04/12/2024, 04/12/2024, 04/12/2024 & 05/12/202] under Section 144C(5) of the Act for the Assessment Year ... 144C(13) of the Income-tax Act, 1961 (Act), in pursuance of the directions dated 4 December 2024, issued by the Hon'ble Dispute Resolution Panel-1, Mumbai (DRP-1) on the following grounds, each of which is without prejudice to and independent of the others On the facts

Fidelity Rutland Square Trust II Strategic Advisers Emerging Markets Fund, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation), Mumbai

The appeals are partly allowed

ITA 2127/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Jun 2025AY 2022-23
For Respondent: Shri Anish Thackar
Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 70Section 70(2)

144B of the Income Tax Act, 1961 [hereinafter referred to as 'the Act'], as per the directions issued by Commissioner of Income Tax [Dispute Resolution Panel (1)], Mumbai-3 [for short 'DRP'] [on 04/12/2024, 04/12/2024, 04/12/2024 & 05/12/2024] under Section 144C(5) of the Act for the Assessment Year ... 144C(13) of the Income-tax Act, 1961 (Act), in pursuance of the directions dated 4 December 2024, issued by the Hon'ble Dispute Resolution Panel-1, Mumbai (DRP-1) on the following grounds, each of which is without prejudice to and independent of the others On the facts

Fidelity Salem Street Trust Fidelity Sai Emerging Markets Index Fund, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(3)(1), Mumbai

The appeals are partly allowed

ITA 2126/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Jun 2025AY 2022-23

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Anish ThackarFor Respondent: Shri Satya Pal Kumar
Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 70Section 70(2)

144B of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’], as per the directions issued by Commissioner of Income Tax [Dispute Resolution Panel (1)], Mumbai-3 [for short ‘DRP’] [on 04/12/2024, 04/12/2024, 04/12/2024 & 05/12/202] under Section 144C(5) of the Act for the Assessment Year ... 144C(13) of the Income-tax Act, 1961 (Act), in pursuance of the directions dated 4 December 2024, issued by the Hon'ble Dispute Resolution Panel-1, Mumbai (DRP-1) on the following grounds, each of which is without prejudice to and independent of the others On the facts

Fidelity Rutland Square Trust II Strategic Advisers Fid Emg Markets Fund, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation )2(3)(1), Mumbai

ITA 2125/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Jun 2025AY 2022-23
Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 70(2)

144B of the Income Tax Act, 1961 [hereinafter referred to as 'the Act'], as per the directions issued by Commissioner of Income Tax [Dispute Resolution Panel (1)], Mumbai-3 [for short 'DRP'] [on 04/12/2024, 04/12/2024, 04/12/2024 & 05/12/2024] under Section 144C(5) of the Act for the Assessment Year ... 144C(13) of the Income-tax Act, 1961 (Act), in pursuance of the directions dated 4 December 2024, issued by the Hon'ble Dispute Resolution Panel-1, Mumbai (DRP-1) on the following grounds, each of which is without prejudice to and independent of the others On the facts

Tata Cummins Private Limited, Pune vs. The DCIT Circle-1-Jamshedpur and the Assessment Unit, Income-Tax Department, NFAC, Delhi, Jamshedpur

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

ITA 430/RAN/2024[2021-22]Status: DisposedITAT Ranchi12 Jun 2025AY 2021-22

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaytata Cummins Private Limited, D.C.I.T., Cummins India Office, Tower-A, 7Th Circle-1, Vs. Floor, Survey No. 21, Balewadi, Pune, Jamshedpur. Maharashtra. Pan No. Aaact 6353 L Appellant/ Assessee Respondent/ Revenue

appeal filed by the assessee against the order of the learned Transfer Pricing Officer (TPO) wherein on the basis of direction of the Dispute Resolution panel-2, New Delhi (Dispute Resolution Panel), the TPO has treated the Research & Development (R&D) expenses incurred by the assessee

Ishares Msci All Country Asia Ex Japan Etf(As A Successor to Ishares Msci All Country Asia Ex Japan Mauritius Co), Mumbai vs. DCIT (Int)-2(2)(2), Mumbai

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

ITA 2154/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

Section 143(3)Section 144C(13)

read with section 144C(13) of the Income Tax Act, 1961 (“the Act”), pursuant to the separate directions issued by the learned Dispute Resolution Panel, Mumbai (“learned DRP") under section 144C(5) of the Act, for the assessment year 2022-23. 2. Since the issues that arise for our consideration

Ishares Msci India Etf(As A Sucessor to Ishares India Index Maruitius Company), Mumbai vs. DCIT (Int)-2(2)(2), Mumbai

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

ITA 2153/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

read with section 144C(13) of the Income Tax Act, 1961 (“the Act”), pursuant to the separate directions issued by the learned Dispute Resolution Panel, Mumbai (“learned DRP”) under section 144C(5) of the Act, for the assessment year 2022-23. 2. Since the issues that arise for our consideration ... Income-tax Act, 1961 (Act), in pursuance of the directions under section 144C(5) of the Act issued by the Hon'ble Dispute Resolution Panel - II, Mumbai (DRP-II) dated 5 December 2024 on the following grounds, each of which is without prejudice to and independent of the others: Ground

Ishares Core Msci Em Imi Ucits Etf, Mumbai vs. DCIT (Int)-2(2)(2), Mumbai

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

ITA 2152/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

read with section 144C(13) of the Income Tax Act, 1961 (“the Act”), pursuant to the separate directions issued by the learned Dispute Resolution Panel, Mumbai (“learned DRP") under section 144C(5) of the Act, for the assessment year 2022-23. 2. Since the issues that arise for our consideration ... Income-tax Act, 1961 (Act), in pursuance of the directions under section 144C(5) of the Act issued by the Hon'ble Dispute Resolution Panel - II, Mumbai (DRP-II) dated 5 December 2024 on the following grounds, each of which is without prejudice to and independent of the others: Ground

Ishares Core Msci Total International Stock Etf (As A Successor to Ishares Core Total International Stock Mauritius Co ), Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(2)(2), Mumbai

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

ITA 2151/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

read with section 144C(13) of the Income Tax Act, 1961 (“the Act”), pursuant to the separate directions issued by the learned Dispute Resolution Panel, Mumbai (“learned DRP”) under section 144C(5) of the Act, for the assessment year 2022-23. 2. Since the issues that arise for our consideration ... Income-tax Act, 1961 (Act), in pursuance of the directions under section 144C(5) of the Act issued by the Hon'ble Dispute Resolution Panel - II, Mumbai (DRP-II) dated 5 December 2024 on the following grounds, each of which is without prejudice to and independent of the others: Ground

Ishares Msci Emerging Markets Etf (As A Successor to Ishares Emerging Markets Index Mauritius Co ), Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(2)(2), Mumbai

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

ITA 2150/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

read with section 144C(13) of the Income Tax Act, 1961 (“the Act”), pursuant to the separate directions issued by the learned Dispute Resolution Panel, Mumbai (“learned DRP") under section 144C(5) of the Act, for the assessment year 2022-23. 2. Since the issues that arise for our consideration

Ishares India 50 Etf (As A Successor to Ishares India Mauritius Co ), Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(2)(2), Mumbai

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

ITA 2149/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

read with section 144C(13) of the Income Tax Act, 1961 (“the Act”), pursuant to the separate directions issued by the learned Dispute Resolution Panel, Mumbai (“learned DRP") under section 144C(5) of the Act, for the assessment year 2022-23. 2. Since the issues that arise for our consideration ... Income-tax Act, 1961 (Act), in pursuance of the directions under section 144C(5) of the Act issued by the Hon'ble Dispute Resolution Panel - II, Mumbai (DRP-II) dated 5 December 2024 on the following grounds, each of which is without prejudice to and independent of the others: Ground

Ishares Msci Em Ucits Etf Usd Dist, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(2)(2), Mumbai

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

ITA 2148/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

read with section 144C(13) of the Income Tax Act, 1961 (“the Act”), pursuant to the separate directions issued by the learned Dispute Resolution Panel, Mumbai (“learned DRP”) under section 144C(5) of the Act, for the assessment year 2022-23. 2. Since the issues that arise for our consideration ... Income-tax Act, 1961 (Act), in pursuance of the directions under section 144C(5) of the Act issued by the Hon'ble Dispute Resolution Panel - II, Mumbai (DRP-II) dated 5 December 2024 on the following grounds, each of which is without prejudice to and independent of the others: Ground

Ishares Msci India Ucits Etf, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation )-2(2)(2), Mumbai

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

ITA 2147/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

read with section 144C(13) of the Income Tax Act, 1961 (“the Act”), pursuant to the separate directions issued by the learned Dispute Resolution Panel, Mumbai (“learned DRP”) under section 144C(5) of the Act, for the assessment year 2022-23. 2. Since the issues that arise for our consideration ... Income-tax Act, 1961 (Act), in pursuance of the directions under section 144C(5) of the Act issued by the Hon'ble Dispute Resolution Panel - II, Mumbai (DRP-II) dated 5 December 2024 on the following grounds, each of which is without prejudice to and independent of the others: Ground

Schwab Emerging Markets Equity Etf, Mumbai vs. Deputy Commissioner of Income Tax International Taxation -4(2)(1), Mumbai

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

ITA 2134/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

read with section 144C(13) of the Income Tax Act, 1961 (“the Act”), pursuant to the separate directions issued by the learned Dispute Resolution Panel, Mumbai (“learned DRP") under section 144C(5) of the Act, for the assessment year 2022-23. 2. Since the issues that arise for our consideration

Ishares Core Msci Emerging Markets Etf (As A Sucessor to Ishares Core Emerging Markets Mauritius Company), Mumbai vs. Deputy Commissioner of Income Tax (International Taxation) 2(2)(2), Mumbai

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

ITA 2085/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

read with section 144C(13) of the Income Tax Act, 1961 (“the Act”), pursuant to the separate directions issued by the learned Dispute Resolution Panel, Mumbai (“learned DRP") under section 144C(5) of the Act, for the assessment year 2022-23. 2. Since the issues that arise for our consideration

ACIT Circle, 3(4), Mumbai vs. Union Bank of India, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 2119/MUM/2024[2020-21]Status: DisposedITAT Mumbai11 Jun 2025AY 2020-21

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiyaआयकर अपील सं./Ita No. 2037/Mum/2024 (निर्धारण वर्ष / Assessment Year :2020-21) आयकर अपील सं./Ita No. 2038/Mum/2024 (निर्धारण वर्ष / Assessment Year :2021-22) Union Bank Of India, Finance & Accounts, Union Bank Bhavan, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai, Maharashtra- 400021 V/S. बनाम Dcit, Circle- (Ltu) 2, Mumbai Room No. 421, 4Th Floor, Aayakar Bhavan, M. K. Road, Mumbai-400020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacu0564G Appellant/अपीलार्थी .. Respondent/प्रतिवादी आयकर अपील सं./Ita No. 2119/Mum/2024 (निर्धारण वर्ष / Assessment Year :2020-21) आयकर अपील सं./Ita No. 2118/Mum/2024 (निर्धारण वर्ष / Assessment Year :2021-22) Acit, Circle-3(4), Mumbai Room No. 559, 5Th Floor, Aayakar Bhavan, M. K. Road, Mumbai-400020 V/S. Union Bank Of India, Finance & Accounts, Union बनाम Bank Bhavan, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai, Maharashtra- 400021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacu0564G Appellant/अपीलार्थी .. Respondent/प्रतिवादी Page 2

For Appellant: Shri C. NareshFor Respondent: Shri Vikas K. Suryawanshi
Section 144Section 14A

completeness, we may also place on record that the fact that in assessee's own case for the assessment year 2012-13, the Dispute Resolution Panel has given relief of Rs.10,81,17,104 on this issue, and likewise for the assessment year 2013-14, the Dispute Resolution Panel ... eagerness to go back to the assessment stage, and claim it as a covered issue before them. The reasoning adopted by the Dispute Resolution Panel, for example for the assessment year 2013-14 (at page 294 of the paper book, and internal page 15 of the respective order

ACIT, Circle -3(4), Mumbai vs. Union Bank of India, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 2118/MUM/2024[2021-22]Status: DisposedITAT Mumbai11 Jun 2025AY 2021-22

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiyaआयकर अपील सं./Ita No. 2037/Mum/2024 (निर्धारण वर्ष / Assessment Year :2020-21) आयकर अपील सं./Ita No. 2038/Mum/2024 (निर्धारण वर्ष / Assessment Year :2021-22) Union Bank Of India, Finance & Accounts, Union Bank Bhavan, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai, Maharashtra- 400021 V/S. बनाम Dcit, Circle- (Ltu) 2, Mumbai Room No. 421, 4Th Floor, Aayakar Bhavan, M. K. Road, Mumbai-400020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacu0564G Appellant/अपीलार्थी .. Respondent/प्रतिवादी आयकर अपील सं./Ita No. 2119/Mum/2024 (निर्धारण वर्ष / Assessment Year :2020-21) आयकर अपील सं./Ita No. 2118/Mum/2024 (निर्धारण वर्ष / Assessment Year :2021-22) Acit, Circle-3(4), Mumbai Room No. 559, 5Th Floor, Aayakar Bhavan, M. K. Road, Mumbai-400020 V/S. बनाम Union Bank Of India, Finance & Accounts, Union Bank Bhavan, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai, Maharashtra- 400021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacu0564G Appellant/अपीलार्थी .. Respondent/प्रतिवादी Page 2

For Appellant: Shri C. NareshFor Respondent: Shri Vikas K. Suryawanshi
Section 144Section 14A

completeness, we may also place on record that the fact that in assessee's own case for the assessment year 2012-13, the Dispute Resolution Panel has given relief of Rs.10,81,17,104 on this issue, and likewise for the assessment year 2013-14, the Dispute Resolution Panel ... eagerness to go back to the assessment stage, and claim it as a covered issue before them. The reasoning adopted by the Dispute Resolution Panel, for example for the assessment year 2013-14 (at page 294 of the paper book, and internal page 15 of the respective order

M/S Union Bank of India, Mumbai vs. DCIT, Circle-(Ltu) 2, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 2038/MUM/2024[2021-22]Status: DisposedITAT Mumbai11 Jun 2025AY 2021-22

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiyaआयकर अपील सं./Ita No. 2037/Mum/2024 (निर्धारण वर्ष / Assessment Year :2020-21) आयकर अपील सं./Ita No. 2038/Mum/2024 (निर्धारण वर्ष / Assessment Year :2021-22)

For Appellant: Shri C. NareshFor Respondent: Shri Vikas K. Suryawanshi
Section 144Section 14A

completeness, we may also place on record that the fact that in assessee's own case for the assessment year 2012-13, the Dispute Resolution Panel has given relief of Rs.10,81,17,104 on this issue, and likewise for the assessment year 2013-14, the Dispute Resolution Panel ... eagerness to go back to the assessment stage, and claim it as a covered issue before them. The reasoning adopted by the Dispute Resolution Panel, for example for the assessment year 2013-14 (at page 294 of the paper book, and internal page 15 of the respective order

M/S Union Bank of India, Mumbai vs. Deputy Commissioner of Income Tax, Circle-(Ltu)-2, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 2037/MUM/2024[2020-21]Status: DisposedITAT Mumbai11 Jun 2025AY 2020-21

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiyaआयकर अपील सं./Ita No. 2037/Mum/2024 (निर्धारण वर्ष / Assessment Year :2020-21) आयकर अपील सं./Ita No. 2038/Mum/2024 (निर्धारण वर्ष / Assessment Year :2021-22) Union Bank Of India, Finance & Accounts, Union Bank Bhavan, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai, Maharashtra- 400021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacu0564G Appellant/अपीलार्थी V/S. बनाम Dcit, Circle- (Ltu) 2, Mumbai Room No. 421, 4Th Floor, Aayakar Bhavan, M. K. Road, Mumbai-400020 .. Respondent/प्रतिवादी आयकर अपील सं./Ita No. 2119/Mum/2024 (निर्धारण वर्ष / Assessment Year :2020-21) आयकर अपील सं./Ita No. 2118/Mum/2024 (निर्धारण वर्ष / Assessment Year :2021-22) Acit, Circle-3(4), Mumbai Room No. 559, 5Th Floor, Aayakar Bhavan, M. K. Road, Mumbai-400020 V/S. Union Bank Of India, बनाम | Finance & Accounts, Union Bank Bhavan, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai, Maharashtra- 400021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacu0564G Appellant/अपीलार्थी .. Respondent/प्रतिवादी Page 2

For Appellant: Shri C. NareshFor Respondent: Shri Vikas K. Suryawanshi
Section 144Section 14A

completeness, we may also place on record that the fact that in assessee's own case for the assessment year 2012-13, the Dispute Resolution Panel has given relief of Rs.10,81,17,104 on this issue, and likewise for the assessment year 2013-14, the Dispute Resolution Panel ... eagerness to go back to the assessment stage, and claim it as a covered issue before them. The reasoning adopted by the Dispute Resolution Panel, for example for the assessment year 2013-14 (at page 294 of the paper book, and internal page 15 of the respective order