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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

Wsg Venture Pvt. Ltd., Kanpur vs. Dct, Circle-2(1)(1), Kanpur

In the result, the appeal of the assessee is dismissed

ITA 211/LKW/2025[2022-23]Status: DisposedITAT Lucknow29 May 2025AY 2022-23

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2022-23 Wsg Venture Pvt. Ltd., Vs. The Dcit, 1-59, Mig, Word Bank Barra, Circle 2(1)(1), Kanpur Kanpur-208027 Pan:Aaccw7342L (Appellant) (Respondent) Assessee By: None Revenue By: Sh. Sunil Kumar Rajwanshi, Addl. Cit Dr Date Of Hearing: 21.05.2025 Date Of Pronouncement: 29.05.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal By The Assessee Against The Order Of The Ld. Pcit-1, Kanpur Passed Under Section 119 Of The Income Tax Act, 1961 On 5.12.2024 Refusing To Condone The Delay In Filing The Income Tax Return For The Assessment Year 2022-23 With The Claimed Refund Of Rs. 10,000/-. The Grounds Of Appeal Are As Under:- “01. That Due To Mistake Of Counsel, The Itr For The Ay 2022-23 Could Not Be Filed Of The Assessee Company, Whereas The Certificate Of The Counsel Was Also Filed, But Ignore The Same & Rejected The Petition Moved U/S.119(2)(B) Of The Act, Which Action Of The Pr. Cit Is Contrary To Fact & Be Quashed. 02. That The Order Passed By The Pr. Cit U/S.119 Of The Income Tax Act Reject The Petition For Condonation Of Delay Moved U/S.119(2)(B) Of The Act Is Not Lawful, Bad In Law, Be Quashed. 03. That The Pr. Cit As Well As Cpc Has Erred On Facts & In Law In Arbitrarily Rejecting The Petition Of The Assessee Company To Rectify The Return Of Income, Which Should Ought To Have Done. A.Y. 2022-23 Wsg Venture Pvt. Ltd. 04. That The Order Passed By The Pr. Cit U/S 119 Dated 05.12.2024 Is Erroneous, Misconceived, Contrary To Facts, Bad In Law & Be Modified.”

For Appellant: NoneFor Respondent: Sh. Sunil Kumar Rajwanshi, Addl. CIT DR
Section 10Section 115VSection 119Section 119(2)(b)Section 12ASection 132Section 143Section 144BSection 147Section 153A

under sub-section (3), of section 143 or section 147 [or section 153A or section 153C] in pursuance of the directions of the Dispute Resolution Panel or an order passed under section 154 in respect of such order,] [(e) an order passed by an Assessing Officer under sub section

Volkswagen Group Technology Solutions India Pvt. Ltd., Pune vs. National Faceless Assessment Center, Assessment Unit Delhi, Delhi

In the result, appeal of the assessee is partly allowed

ITA 1950/PUN/2024[2020-21]Status: DisposedITAT Pune28 May 2025AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1950/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Volkswagen Group Technology V National Faceless Solutions India Pvt. Ltd., S Assessment Center, Embassy Techzone, 9Th Floor, Assessment Unit, Delhi. 1.3 Congo Building, Rajiv Gandhi, Infotech Park, Infotech Park Hinjavadi, Pune – 411057. Maharashtra. Pan: Aafcv1368L Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 15/05/2025 Date Of Pronouncement 28/05/2025

Section 143(3)Section 144BSection 153Section 92C(1)Section 92C(3)

No.1950/PUN/2024 [A] “1. On the facts and in the circumstances of the case, and in law, the Ld. Assessing Officer ('AO') / Ld. Dispute Resolution Panel ('DRP') has erred in proposing to enhance the income of the Appellant by INR 15,77,44,750 by holding that the international transaction ... comparable companies is enclosed at page 189 of the paperbook.” Submission of ld.DR : 3. Ld.DR for the Revenue relied on the order the Dispute Resolution Panel and Transfer Pricing Officer(TPO). Findings & Analysis : 4. We have heard both the parties and perused the material placed before us. In this case